PRIVACY POLICY

STASHLETE, INC.

PRIVACY POLICY

Last revised: April 2024 [    ]

This Privacy Policy describes how Stashlete, Inc. (“Company”, “we”, or “us”)  collects, uses, protects, and discloses personal information from (1) websites operated by us Privacy Policy, including, but not limited to, https://www.stashlete.com/ (the “Websites”); and (2) electronic communications, including, but not limited to, email and text message, from or to us (the “Electronic Communications”) (collectively, the Websites and Electronic Communications are referred to herein as the “Services”). References to “you” or “your” in these Terms of Use include you and, if acting on behalf of a third party or your employer, any such third party or employer.

This Privacy Policy does not apply to information collected by us offline or through any other means not listed above and information collected through any other third-party application, social media platform, or content that may be linked to or accessible from use of the Services.

By using the Services, you agree to the terms and conditions of this Privacy Policy and if you do not agree with our policies and practices, your choice is to not use the Services.

This Privacy Policy may change from time to time without advanced notice, as outlined below in the Changes to This Privacy Policy section. Continued use of any Service after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Information You Provide or That We Collect About You

“Personal Information” is information that identifies or may be used reasonably capable of identifying, directly or indirectly identify, an individual. Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

You may provide and/or we collect several types of information about the users of the Services, including:

  • Contact Information: Name, postal and email address, telephone and fax number.
  • Financial Information: Information from financial partners when you connect your financial account.
  • Internet, Network, and Device Information such as device model, IP address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers.
  • data from other sources such as identity verification, or
  • ANY OTHER INFORMATION COLLECTED BY US IN CONNECTION WITH YOUR USE OF THE SERVICES THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER APPLICABLE LAW

Information We Collect Through Automatic Data Collection Technologies

As you interact with the Services, we may automatically collect Personal Information related to your use and interactions with our Services. This information includes:

  • Device information such as IP address, unique identifiers, device identifiers, device type, browser type, operating system, time zone, and similar device and usage information.
  • Usage data such as browsing history, search history, product interaction, crash data, performance, and other diagnostic data, and other usage data.
  • Online activity information such as links clicked, page views, searches, features used, items viewed, time spent on the Website, information uploaded, and items in your cart. For more information, see Cookies and Other Technologies.

Information We Collect from Third-Party Sources

We may collect Personal Information about you from third-party sources, including when you use our Services with third-party products and sources. This information includes:

  • Information from third party providers such as those providers whose products or services are used to access our Services or other third party products or services offered through our Services.
  • Information from partners such as how you engage with marketing campaigns or events that we sponsor.

  • Third parties control the information they collect and share about you. For more information, please consult their respective privacy policies.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

  • Provide the services and products you request. We process your Personal Information to provide you with the Services and products you have requested.
  • Improve our Services. We use Personal Information to improve our offerings and for internal purposes such as auditing or data analysis, and for troubleshooting issues.
  • Communicate with you. We process your Personal Information to respond to communications from you, contact you about your transactions, or market our products and Services. We also use your contact details to personalize communications and advertisements regarding our products and Services that may be of interest to you. Additionally, if you contact our customer services representatives, we will use your information to help you resolve a problem and answer your question. In many cases, to use particular functions of our Services, you may need to provide us with additional information.
  • Prevent and investigate fraud. We process Personal Information to protect the rights of individuals, employees, and the Company and to prevent loss, fraud, abuse, illegal use, unauthorized use, and other misuse and to prevent violations of our Terms of Use.
  • Personalize and understand your experience. We process Personal Information, including inferences, to personalize our Services.
  • Security and technical operations. We process Personal Information to secure, operate, improve, and maintain our products and services. We may use information to help us diagnose technical and service problems.
  • Comply with law. We may use Personal Information to comply with applicable law, such as proceedings, process, court orders, or governmental requests.

How We Disclose Personal Information

We may disclose Personal Information as follows:

  • Affiliates and subsidiaries. We may disclose information to our affiliates, subsidiaries, and service providers for business purposes such as providing the Services and other business purposes (such as cloud-hosting platform providers analyzing data, providing marketing assistance, financing, and processing payments).
  • Service Providers. We may disclose information to third parties in order to complete your transaction, administer marketing campaigns and targeted advertisements, and to protect the security and integrity of the Services and correct any technical problems and malfunctions. We may engage third parties to act as our service providers and perform certain tasks on our behalf including, but not limited to, analyzing customer data, providing marketing assistance, financing, processing payments, and processing or storing data in connection with your use of our Services and delivering products to customers. For more information, please see Cookies and Other Technologies.
  • Other Third Parties. We may disclose information with your consent or at your direction. We may disclose information to the extent necessary for the purposes of law enforcement or other issues of public importance. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, rights, property, or other users.
  • Parties to a Business Transaction. We may disclose information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Snipe’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Snipe’s about our Services users is among the assets transferred.
  • Consent. We may disclose your information in other way with your consent.

Security

We work to protect your Personal Information from loss, misuse, or unauthorized alteration by using a variety of technical, administrative, and organizational security safeguards, coupled with security procedures and practices. Although the Company employs commercially reasonable measures to maintain security, we cannot guarantee that your information will not be intercepted by third parties’ illegal efforts. It is your responsibility to maintain the privacy of your username and password. Unauthorized use of your registered account with us will enable access to your Personal Information. Please keep your username and password in a safe and secure place.

Third-Party Tracking & Websites

Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior to and after visiting the Services. Please note, however, that we cannot control third-party tracking and there may be some third-party tracking that occurs without our knowledge or consent.

The Services may also contain links to other websites which are not controlled by us. These links are made available to you as a convenience, and you agree to use these links at your own risk. The Company disclaims any responsibility for the privacy practices or the content of such other websites. If you navigate to a third-party website from our Services, we strongly encourage you to review and become familiar with that third-party website’s own privacy policy and statements.

Notice to Individuals Outside the United States

The Services are intended only for individuals located in the United States. If you are located outside of the United States, any information you provide to us will be transferred to and stored in the United States and that, by submitting information to us, you explicitly authorize its transfer and storage within the United States. We will protect the privacy and security of Personal Information according to this Privacy Policy regardless of where it is processed or stored.

Cookies and Other Technologies

The Company, our service providers, and third parties may use cookies and other technologies such as pixels and web beacons, from third parties and service providers to help personalize your online experience, remember your preferences, analyze the use of the Website, advertise our Services to you, and maintain security of the Services. These technologies help us understand how users interact with our Services, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our Services. Through the use of cookies and other similar technologies, information about video materials or services you engage with on the Website may be disclosed incidentally in the ordinary course of business.

To the extent that cookies and other similar tracking technologies are deemed to be a “sale” / “sharing,” which includes targeted advertising, as defined under applicable U.S. state laws, you can opt out of these online tracking technologies by submitting a request via [     ], which is available at [     ]. Please note, some features of our Website may not be available or function as intended as a result.

To learn how to opt out of certain ad network interest-based advertising in the U.S., please visit YourAdChoices and Network Marketing Initiative websites. Choices you make may be browser and device specific. In addition, your mobile device settings may allow you to limit your device from sharing certain information for advertising purposes. Additional information about opting out of targeted advertising is included in the U.S. State Data Privacy Laws section below.

Children Under the Age of Thirteen (13)

The Services do not target anyone under eighteen (18) years of age. We do not knowingly collect information from children under the age of thirteen (13). If you are under the age of thirteen (13), do not use or provide any information through the Services. If we learn that we have collected or received Personal Information from a child under that age of thirteen (13) without verification of parental consent, we will delete that information.

Changes to This Privacy Policy

It is our policy to post any changes we make to this Privacy Policy on this page. If we make material changes to how we treat our user’s Personal Information, we will notify you through a notice on the home page(s) of the Websites. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting the Websites and this Privacy Policy to check for any changes.

U.S. State Data Privacy Laws

The Company processes your Personal Information in accordance with applicable U.S. state data privacy laws. Consistent with applicable law, residents of these states may exercise the rights described in this section. Please note that consumer rights vary from state to state and some states do not provide consumers all of the rights detailed below.

Personal Information Collection, Uses, and Your Rights

U.S. state data privacy laws require the Company to disclose the categories of Personal Information collected, from whom Personal Information is collected, and how such Personal Information is used. Please see the sections above for more information: “Personal Information We Collect,” which details the sources and categories of Personal Information the Company collects and “How We Use Personal Information,” which details how your Personal Information is used.

Categories of Personal Information Disclosed and Categories of Recipients

We disclose the following categories of Personal Information for a business purpose:

  • Contact information, internet, network and device information, commercial information and communication information with service providers and third parties, such as advertising networks, analytics, and social media networks.
  • Contact information, commercial information and payment information with businesses and service providers who process payments.

 

Right to Opt-Out of Sale/Sharing/Targeted Advertising

In addition to the categories of information disclosed for a commercial purpose in the section above, our Services use cookies and other online tracking technologies that may be considered a “sale” / “sharing” under applicable law, otherwise known as “targeted advertising.” You may exercise your right to opt out of the “sale” / “sharing” of your Personal Information by….[  ]

Residents of certain states may opt out by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Categories of Personal Information disclosed that may be considered “sale” / “sharing” include Contact Information, Device Information, and Internet/Network Activity. Categories of third parties to whom Personal Information was disclosed that may be considered “sale”/ “sharing” include certain advertisers and marketing partners, data analytics providers, and social media networks.

Right to Access, Know, and Correct

Residents of states with data privacy laws have the right to know what Personal Information was collected and the right to know the business and commercial purpose with which the Company  processed the Personal Information over the past 12 months. Residents also have the right to correct any Personal Information maintained by the Company that may be incorrect. Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of Personal Information collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • Sales, identifying the Personal Information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
  • The specific pieces of Personal Information we collected about you.

Right to Delete

Residents of states with data privacy laws have the right to request that the Company delete any Personal Information collected and retained, subject to certain limitations. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) and as permitted by applicable law. We will delete or deidentify Personal Information not subject to an exception from our records and will direct our service providers to take similar action.

Exercising Your Rights

To exercise your rights described above, please submit a request by either:

  • Calling us at [    ]
  • Visiting DSAR Request Form 

Only you, or a natural person or an authorized agent may make a verifiable consumer request related to your Personal Information.

You may only submit a request to know twice within a 12-month period. Your 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 verifying your identity and describing your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.

You do not need to create an account with us to submit a request. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

Authorized Agents

If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable law. If a power of attorney is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. If you’re an authorized agent making a request, we may ask for additional information to confirm your identity and authorization.

Response Timing and Format

We will acknowledge a verifiable consumer request within ten (10) days of receipt, where applicable law requires, and we will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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.

Residents of certain states may have the right to appeal our decision with respect to a request. To appeal a decision, please contact us through the ways listed below or any method outlined in the decision.

Non-Discrimination and No Retaliation

We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

California Shine the Light

Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information that includes a list of all third parties to which the Company has disclosed Personal Information, as defined in California Civil Code Section 1798.83(e), during the preceding year, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. California residents may request this information in writing by contacting us by email to info@stashlete.com with “California Privacy Request” in the subject line. In your request, please attest to the fact that you are a California resident and provide a current California address for your response.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Stashlete, Inc.

HQ: Atlanta, GA

Email: contact@stashlete.com