LAST UPDATED: April 7, 2020
Note: This statement applies solely to information collected at or through the Site. However, content presented on the Site may link to other online destinations, so we advise you carefully review their respective privacy policies. Please be aware that we are not responsible for the contents and privacy practices of such other sites.
CALIFORNIA PRIVACY RIGHTS
Section 1798.83 of the California Civil Code provides that residents of California can obtain certain information about their Personal Information (as defined under Section 1798.83(e)(6) of the California Civil Code) that companies have shared with third parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third parties. Personal Information, as defined under the California Civil Code, includes, but is not limited to, data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller. We extend these same rights to all Sqweee users, regardless of your place of residence. To request a copy of your Personal Information maintained by us, please contact us at email@example.com.
INFORMATION YOU PROVIDE TO US
In order to provide you with the best experience via our Site, Sqweee collects Personal Information through the Site at several points. For example, for event guests to register for event notifications through the Site, we require your email address and will provide it to the Sqweee member running the event through our Site. For members of Sqweee who will be holding and running events through the Site, we require your credit card or debit card information. However, in any event, we do not collect any Personal Information that you do not expressly provide and will not sell, rent, or share your Personal Information to any third party for marketing purposes without your consent.
We (or our service providers) collect information from you when you: (1) purchase products or services from us on our Site; (2) create an account with us (“Account”), or otherwise sign up for a service or feature; (3) complete a survey; (4) submit an RSVP; (5) attend an event; (6) communicate with us via third-party social media sites; (7) apply for a job or to be a consultant or attendee with us; or (8) contact us, or otherwise communicate with us or provide information to us.
Sqweee guests or attendees to member events through the Site are not required to have an Account with us and need only provide their name to RSVP for or attend an event on our Site, and their email address to receive certain optional features from our Site.
When you visit our Site, we also collect anonymous information such as your IP address or domain name to analyze Site traffic, but this information is not personally identifiable. We will use this information to help diagnose problems with our server, to administer our Site, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.
In some cases, you may provide information to us about another person, such as when you share Site content or send a message to a friend through our Site, or if a Sqweee member holding events through the Site provides attendee information to us. In such cases, you represent that you have the authorization of such person to provide us with such information.
We may combine your (and others’) information that we’ve collected from you (or others) with information we may receive from other sources, such as third-party social media platforms (e.g., when you choose to log in to our Site through a third-party social media platform, subject to your actions and settings thereon), address update services, and co-promotion partners. By accessing our Site, you signify your consent to the above collection of your Personal Information.
If you do not want us to collect your Personal Information, please do not provide it to us. Members can update their information or change membership plan settings by accessing their Account via the Site. In addition, you can revoke your consent in accordance with the procedures set forth below.
If you receive an email or other correspondence requesting that you provide any sensitive information (including your Site password or credit card information) via email or to a website that does not seem to be affiliated with our Site, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us at firstname.lastname@example.org.
To use certain aspects of our Site, such as setting up and running events through our Site, we require credit or debit card account information. By submitting your credit or debit card account information through the Site, you expressly consent to the sharing of your information with third-party subscription, billing, and payment processors. These third parties store and utilize your credit or debit card account information so you can use our Site and its services in the future. Sqweee does not have, store, or maintain direct control over, or responsibility for, your complete credit or debit card account information.
While we require that such third parties use reasonable procedures to help protect your credit or debit card information, we cannot guarantee that transmissions of your credit or debit card account information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
As part of setting up your Sqweee Account, you will be asked to add the direct sales business or businesses to which you are affiliated to your Account Profile page. In most cases, you will also need to enter your unique “Consultant ID” for each business that you are affiliated with before you can use certain aspects of our Site.
If you are affiliated with a direct sales company that Sqweee has a partnership with, that business may be automatically added to your Account Profile page, and your Consultant ID, Personal Website URL, or other identifying features may automatically be entered for you. As part of the partnership, your Sqweee account may be linked to your consultant account with your direct sales company, so that we are able to provide additional partner-specific features to you. These links may enable Sqweee to access certain information from those accounts. By creating and using a Sqweee Account through a partner company, you agree to the establishment and use of these links.
GUESTS OF MEMBER EVENTS ON SQWEEE
While submitting an RSVP to an event hosted through the Site, guests enter their name and are given the option to enter their email address to receive notifications and reminders about the event. Guests who enter their email address will be automatically emailed by the Site at the following times:
- To confirm we received their RSVP
- If this event is rescheduled
- 2 hours before this event is scheduled to start
- When this event is started
- When this event is ended
In addition, for guests who opted to enter their email address to receive notifications:
- Those guests can prompt the Site to email their favorites lists (i.e. the products they starred as favorites) to themselves via tools in the event, and after the event has been ended.
- The member hosting their event can prompt the Site to email those guests their favorites lists during the event, and after the event has ended.
All of the above emails will be sent by Sqweee Notifications (email@example.com) on behalf of the member.
If you entered your email address while submitting an RSVP to sign up for automated event notifications and reminders from the Site, and wish to stop receiving those reminders, you can cancel your RSVP or update your RSVP to remove your email address, and the Site will stop emailing you and remove your email address from the member’s view. After the event has started, you’ll be able to remove your email address from the About This Event section, accessed via a button in the menu with a circled-i icon. You can also email Sqweee at firstname.lastname@example.org to request that we remove your email address from the Site.
SITE INFORMATION & OTHER INFORMATION COLLECTED AUTOMATICALLY
Site Usage Information includes, but is not limited to: (i) your browser type, device type, carrier (if applicable), device address, operating system, operating system address, IP address, and the domain name from which you accessed a Site; (ii) information about your region, continent, country, city, zip code, time zone, and general location; and (iii) information about your browsing activities on and through a Site (also known as “Click Stream” data), such as (a) the date and time you visit our Site, (b) the areas or pages of a Site that you visit, (c) the amount of time you spend viewing a Site or specific areas of a Site, (d) the number of times you return to a Site or a specific area of a Site, (e) the websites or pages you visited prior to visiting a Site, (f) the websites or pages you visit after you leave a Site; (g) searches you have performed on a Site and on other websites that led you to our Site; (h) social plug-ins with which you have interacted on our Site; and (j) other similar Site usage data (collectively, the “Site Usage Information”).
If you provide or connect your third-party account credentials to an account with our Site, some content and/or information in those accounts may be transmitted into your account with us. For example, when you connect with Facebook, we receive and collect your name, email address, and profile photo.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We may also use web beacons (also known as “clear GIFs” or “pixel tags”) for similar purposes as cookies. These beacons are typically one-pixel images that are embedded in the Site or in a communication, such as an email message. These technologies help us to verify when a certain page of a Site is viewed, when a message is opened, and when links or other content in a message are clicked or viewed.
We may use third-party web analytics services, such as Google Analytics and Adobe services, to help us track and analyze the use of our Site and to measure the effectiveness of our advertising, Site content, and communications. These service providers’ tools, including, for example, cookies and web beacons, help us to gain this understanding.
DO NOT TRACK
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our website. To learn more about browser tracking signals and “Do Not Track,” please visit https://allaboutdnt.com.
We may use the information we collect from and about you (including both Personal Information and Site Usage Information) for a variety of purposes, including but not limited to the following:
(i) To fulfill your requests for products and services and RSVPs to events and to keep you informed about your Account and any events you may have signed up for; (ii) to contact you (via postal mail, email, and the like) with promotional materials about us, our products, our services, and our events, as well as about select partners; (iii) to contact you when necessary or appropriate; where appropriate, for market research and to review and improve our merchandise selections, customer service, online and offline operations, and overall shopping experience; (iv) to protect the security or integrity of the Site and our business; (v) and otherwise, with your permission or as permitted by law.
We (and our service providers) also analyze and use Site Usage Information and information collected through cookies, web beacons, and other tracking technologies, alone and in combination with Personal Information, to assess the behavior of our users, to measure the interest in and use of the Site and communications, and to customize the Site and our communications with you. We do this both on an individual basis and in the aggregate.
This table shows you a description of all the ways we plan to use Personal Information, and which legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/ Activity||Type of Data||Lawful Basis for Processing|
|To register new member accounts|
|Performance of a contract with you|
To deliver membership benefits, including:
(a) Managing free trials, payments, fees, and charges
(b) Collecting money owed to us
Performance of a contract with you
Necessary for our legitimate interests (including to recover debts due to us)
To deliver to members the guest information they need to effectively run their direct sales businesses, including:
(a) Name and contact information provided
(b) Date and time of RSVP submission and event attendance
(c) Answers to survey questions
(d) Information provided, such as when chatting
(e) Actions taken on the Site, such as products starred as favorites
(f) Results of interactive posts on the Site, such as the outcome of spinning a prize wheel
Performance of a contract with you
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy
To display in publicly accessible events the content and other information provided on the Site, including:
(a) Text, graphics, videos, products, and other information that together makes up an event
(b) Names of attendees
(c) Answers to survey questions
(d) Chat messages
(e) Prizes won
Performance of a contract with you
Necessary for our legitimate interests (for running our business and provision of administration)
To deliver to guests information on events they’ve submitted an RSVP for or attended, including:
(a) Reminders and notifications of changes to event status
(b) Products starred as favorites
(c) Consultant’s and host’s name and contact information
Performance of a contract with you
Necessary for our legitimate interests (for running our business and provision of administration)
|To use data analytics to improve our website, services, marketing, customer relationships, and experiences|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)|
|To prevent and detect unlawful acts|
Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring)
Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement
|In order to resolve legal claims or disputes involving you or us||All relevant data categories, depending on the nature of the allegation or claim||Necessary to bring or defend a claim|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)
Necessary to comply with a legal obligation
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
We may disclose information we collect (including Site Usage Information and Personal Information) in the following ways to third parties, to the extent permitted by law:
- To our service providers and suppliers, who collect or use such information for us or on our behalf (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, and other similar entities that help us to operate the Site and/or provide functionality, content, and services);
- Our affiliated entities;
- Auditors and professional advisers like bankers, lawyers, accountants, and insurers;
- As necessary, if we believe that there has been a violation of the Site’s Terms of Service or any other policy of the Site, or if we have reason to believe that our rights or property, or the rights or property of any third party, may be or have been harmed;
- To respond to subpoenas or other judicial processes, or to provide information as requested by law;
- In the event that Sqweee or substantially all of its assets are acquired by one or more third parties as a result of an acquisition, merger, sale, consolidation, bankruptcy, liquidation, or other similar corporate reorganization, where your information may be one of the transferred assets;
- As otherwise, with your permission or as permitted by law.
YOUR CHOICES / YOUR PRIVACY RIGHTS / HOW TO UNSUBSCRIBE
If you would like to opt out of receiving emails or direct mail from us, please contact us at email@example.com. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your Account, relationship, activities, transactions, and communications with us.
By consenting to this privacy notice you are giving us permission to process your Personal Information specifically for the purposes identified.
Where we are asking you for sensitive Personal Information we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting us at firstname.lastname@example.org. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
MAINTENANCE AND PROCESSING OF INFORMATION IN THE U.S. AND OTHER COUNTRIES
Your personal and other information may be stored, transferred, and processed in and to the United States. By providing Personal Information to us, you consent to the collection, maintenance, processing, and transfer of such information in and to the United States and other countries and territories, pursuant to the laws of the United States or such other jurisdictions, which may provide lesser privacy protection than the laws of other countries, and you acknowledge that your information may thus be subject to U.S. laws and accessible to the U.S. government, courts, law enforcement, and regulatory agencies.
ACCESS TO YOUR PERSONAL INFORMATION
At any point while we are in possession of or processing your Personal Information, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organization.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to opt-out of information sales – you have the right to opt-out of the sale of your personal information to third parties. You may do so by contacting us at email@example.com.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review – in the event that the Company refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your Personal Information.
To provide you with increased security, access to certain Personal Information stored in your Account is protected with your username and password. You are responsible for maintaining the confidentiality of your Account credentials, and we strongly recommend that you do not disclose your account username or password to anyone. We will never ask you for your password in any unsolicited communication. Please notify us immediately of any unauthorized use of your Account credentials or any other suspected breach of security.
The Site is not directed to children under the age of eighteen (18). If you are under eighteen (18), do not provide your Personal Information on or through the Site. We do not knowingly collect on the Site any Personal Information from children under eighteen (18). Users outside of the United States who are below the age of eighteen (18) (or the age of the majority in the applicable jurisdiction) should not use the Site or our services without authorization from a parent or legal guardian. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us at firstname.lastname@example.org. Moreover, the CCPA prohibits us from selling any Personal Information of children under the age of sixteen (16) without express consent. Therefore, unless we have such consent, we will not under any circumstances knowingly sell such Personal Information.
We will process and store the Personal Information for only so long as necessary to provide our services to you and/or as required by applicable law.
HOW WE USE THE PERSONAL INFORMATION COLLECTED ABOUT YOU
We will process (collect, store and use) the information you provide in a manner compatible with the GDPR, CCPA, and other applicable law. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Sqweee is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Information may be held in addition to these periods depending on individual business needs.
HOW TO FIND OUT PERSONAL INFORMATION HELD BY SQWEEE
At your request, we can confirm what information we hold about you and how it is processed. If the Site does hold Personal Information about you, you can request the following information:
- Identity and contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Sqweee or a third party, information about those interests.
- The categories of Personal Information collected, stored, and processed.
- Recipient(s) or categories of recipients that the data is or will be disclosed to.
- If we intend to transfer the Personal Information to a third country or international organization, information about how we ensure this is done securely. The EU has approved sending Personal Information to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict, or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the Personal Information and the possible consequences of failing to provide such data.
- The source of Personal Information if it wasn’t collected directly from you.
- Any details and information of automated decision-making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
Sqweee accepts the following forms of ID when information on your personal data is requested: Passport, Driver’s License, or other valid photo ID.
In the event that you wish to make a complaint about how your Personal Information is being processed by Sqweee or third parties, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Sqweee’s data protection representatives.
To contact us:
c/o Sqweee LLC
1919 SW Pine Rd
Port Orchard, WA 98367
CHOICE OF LAW AND FORUM