Privacy Policy

Last updated: May 11, 2020

This Privacy Policy (this “Privacy Policy”) outlines how LLC and its affiliates (collectively, “”, the “Company”, “we, “our, or “us”) processes the information that we collect about you through our websites, mobile applications, and other online services (collectively, the “Services”) and when you interact with us, such as through our customer service channels.

We use your data to provide and improve the Services.  By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy.  Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below.  We may provide additional disclosures or information about the data processing practices of specific Services.  These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.  If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.


Collection and Use of Information

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you.  You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Information Collected from Third Parties.  From time to time, we may obtain information about you from third party sources as required or permitted by applicable law.  These sources may include:

Use of Data

We use the collected data for various purposes, including to:

Sharing of Anonymized Information

Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual.  Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data.  To the extent permitted by law, we may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats.  To the extent permitted by law, we may perform our own analytics on anonymized data or enable analytics provided by third parties.  Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR).  If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.  We may process your Personal Data because:

Retention of Data.  We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.  We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes.  Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Disclosure of Data

Legal Requirements.  We may disclose your Personal Data in the good faith belief that such action is necessary to:

Security of Data.  The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is completely secure.  While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.  

Your Data Protection Rights under the General Data Protection Regulation (GDPR).  If you are a resident of the European Economic Area (EEA), you have certain data protection rights.  We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.  If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.  In certain circumstances, you have the following data protection rights:

Please note that we may ask you to verify your identity before responding to such requests.  You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data.  For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We share personal data with certain authorized Service Providers who help us run and protect our business.  These Service Providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyze the use of our Service.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us.  If you click a third-party link, you will be directed to that third party’s site.  We strongly advise you to review the Privacy Policy of every site you visit.  We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services.  In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information.  If you believe that we might have any information from a child under 13 years of age, please contact us at

California Residents

If you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties’ direct marketing purposes.  To the extent we share your personal information in this way, you may receive the following information:  (a)┬áthe categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and (b)┬áthe names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions.  Any terms defined in the CCPA have the same meaning when used in this California Residents section.

Should we engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you in your account.  You can exercise your rights by contacting us via email at so that we may consider your request.

As a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf.  We may verify the request by asking you to provide information that matches information we have on file about you.  You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

Changes to this Privacy Policy

We may change this Privacy Policy.  If we make any changes, we will change the “last updated” date above.  You are advised to review this Privacy Policy periodically for any changes.

Our Contact Information

We welcome your comments or questions about this Privacy Policy.  You may also contact us at: