LAST UPDATED: December 20, 2019
When you register on our Site, you hereby agree and acknowledge that your personal information will be placed into the Samples Avenue™ database and that such personal information shall be shared with third parties for marketing purposes.
NOTICE OF COLLECTION OF PERSONAL INFORMATION
This Policy provides notice to users, including those who are California residents and fall within the definition of “consumers” as provided for in the California Consumer Privacy Act of 2018 (“CCPA”), that we collect Information. As required by the CCPA, the following sections of the Policy also details the categories and sources of Information collected and the business and commercial purposes for the collected Information. We also include a description of rights afforded to California consumers at “RIGHTS OF CALIFORNIA USERS WITH REGARD TO THEIR INFORMATION” including rights to know the Information we have collected and sold and the right to opt-out from the sale of Information and the right to deletion.
Your California Privacy Rights
If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: email@example.com; send mail to: Tagadamedia LLC, 350 Lincoln Rd., Miami, FL 33139; or call us at: 1-855-378-7943.
Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at: firstname.lastname@example.org; send mail to: Tagadamedia LLC, 350 Lincoln Rd., Miami, FL 33139; or call us at: 1-855-378-7943. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.
Browser “Do Not Track” Signals. Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for interest-based advertising. As required by CalOPPA, we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a user to one of our Websites has activated the “do-not-track” setting on her/his browser.
NEVADA PRIVACY RIGHTS
Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about the Nevada State residents to any third party data broker(s). Covered information includes a consumer’s name, postal and email addresses, telephone number and Social Security Number, and includes the Information described above in the “TYPES/CATEGORIES OF INFORMATION WE MAY COLLECT REGARDING USERS” section. If you are a Nevada State resident and you wish to exercise your right to request that we to stop the sale of your Information to third party data brokers, please submit your request by clicking on the link “Do Not Sell My Personal Info” or emailing email@example.com with the subject line “Nevada Privacy Rights.” In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the Website that you visited and the email address you registered with. Please allow thirty (30) days for a response.
Personal Information that We Collect
How We Use Personal Information
By submitting your personal information by and through the Samples Avenue™ Offerings, you agree that we may share, sell, rent, lease or otherwise provide that personal information to any third party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to our users. These businesses and third parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. We will also use your personal information to send you promotional messages regarding various Samples Avenue™ products and/or services, as well as third party products and/or services that we think may be of interest to you.
We may also employ third parties and individuals to perform certain functions on our behalf including helping us operate the Samples Avenue™ Offerings and/or to administer related activities on our behalf. Examples include sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users’ personal information as needed to perform their functions for us but we do not permit them to use user personal information for other purposes.
Additionally, we purchase and manage e-mail lists generated by third parties. Users may remove themselves from a specific mailing list by utilizing the unsubscribe options that are present and available at the end of each piece of e-mail that we send.
We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience on the Site and/or to contact you when necessary in connection with transactions entered into by you through the Samples Avenue™ Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our business. We may also combine the information we have gathered about you with information from other sources.
By registering at the Site, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
Non-Personally Identifiable Information
Demographic Information and Aggregate Data
Aggregate and demographic data is data that describes the demographics, usage or characteristics of our participants as a group, without disclosing personally identifiable information. We use demographic information to tailor the Samples Avenue™ Offerings to the interests of our users. Demographic information is shared with third party advertisers so that they can tailor their advertisements to the appropriate audience. Demographic information may also be shared with other third parties.
Your IP Address
Each time that you visit the Site, our web server automatically recognizes your IP address and the web page from which you came. Your IP address is used to help identify you and to gather broad demographic information about you. We also use your IP address to help diagnose problems with our servers, to administer the Site and to better serve you in using the products, services and other features contained within the Site.
Cookies and Action Tags
The first time that a user provides an e-mail address in connection with her/his activities at the Site, we assign an identification number to that e-mail address and deploy a cookie to the applicable user’s PC. Whenever that user comes back to the Site using the same PC, the cookie allows the Site to identify the user and to recall the user’s e-mail address. If, at any time, a user provides other information in connection with her/his activities on the Site (such as name, address, birth date, gender, etc.), we may store that information, along with the user’s e-mail address, in our user database. We may use the information stored in our database: (a) to effectuate the purpose or transaction for which the information was originally provided by a user; (b) to pre-populate information fields in the event that user wishes to purchase products and/or services or sign up for and/or subscribe to services, promotions or other offers in the future; (c) to ensure that a user will not be repeatedly exposed to the same advertisements, offers and/or promotions while visiting the Site; and/or (d) to, in connection with regular communication with a user, include offers, promotions or advertisements that were historically, or are likely to be, of interest to that user. To find out more about cookies, please visit www.cookiecentral.com. To disable and reject cookies, adjust the settings via the toolbar options menu of your Internet browser. Cookies placed by members of the Digital Advertising Alliance may be opted out of by visiting optout.aboutads.info.
Action Tags, Web Beacons and other Data Collection Methods
An action tag or a web-beacon (also known as a clear gif or a pixel tag) is a method used to track responses or actions by visitors who view certain advertisements and/or other information on the Site. Action tags are 1×1 pixel images embedded in a website page that are used to transparently collect information. We may use action tags to count the number of times that visitors click on a particular banner ad or visit the pages of the Site and to provide information about what products/services are viewed or purchased. We reserve the right to retain this cookie and action tag data indefinitely, and to share information generated by these cookies and action tags with our advertisers, affiliates and service providers.
The Samples Avenue™ Offerings may contain links to other third-party owned and/or operated websites including, but not limited to, the websites of our Merchants and Third-Party Providers. Samples Avenue™ is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of their third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Samples Avenue™ has no responsibility or liability relating to them.
Samples Avenue™ provides its users with the opportunity to receive special offers, products and/or services from third parties including, but not limited to, our Merchants and Third-Party Providers. Where you indicate the desire to receive certain offers, products or services from a third party during the applicable information collection process, your personally identifiable information that was provided during that Samples Avenue™ information collection process will be shared with the applicable third party so that such third party may provide its product or service to you and so that you do not have to complete another information collection form (or re-supply the same information) to purchase or receive that product or service.
Our surveys may ask health-related questions which we may share with our third-party marketing partners who advertise health-related products and services on our Websites, or who otherwise promote health-related products or services. We will use this health information – with your consent – to display offers for health-related products and services or to provide Information to these providers so they can contact you.
MEDICARE SUPPLEMENT PLANS DISCLOSURE
Some of our third-party advertisers offer Medicare Supplement plans. Medicare Supplement plans are not connected with or endorsed by the U.S. Government or the Federal Medicare program and all related offers on our Websites comply with applicable Federal civil rights laws and do not discriminate on the basis of race, color, national origin, age, disability, or sex.
The privacy of your personal information is very important to us. As such, we endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline).
Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. The servers that we store personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure.
Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software constitutes a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data by or through the Samples Avenue™ Offerings is at your own risk.
All of our users’ personal information is restricted in our offices. Only employees or third party agents who need personal information to perform a specific job function are granted access to personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
No information should be submitted to, or posted at, the Site by visitors under eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age). Persons eighteen (18) years of age (or the applicable age of majority, if greater than eighteen (18) years of age) are not permitted to access the Samples Avenue™ Offerings and we do not knowingly collect personal information from such individuals. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
CALIFORNIA NOTICE REGARDING CATEGORIES, SOURCES AND BUSINESS AND COMMERCIAL USES OF INFORMATION
The following chart contains the categories of information, as enumerated in CCPA Sec. 1798.140(o), of Information we collect, use, disclose and sell, the sources of the Information and our business and commercial uses of such Information:
|Category||Category Name/Description||1. Sources||2. Business Use||3. Commercial Use|
|A||Identifiers – name, postal, email and IP address, telephone number||User provided on registration, customer service inquiries and claim forms; related and 3rd party sources to verify and/or augment user supplied information||Operational purposes including determining survey questions, optional offers and deals to be displayed; customer service; fraud & security incidence detection; pre-population of user forms; website improvement||Sold to third parties for marketing purposes; shared with third parties to determine deals to be offered and to pre-populate order forms|
|B||Personal information categories listed in the California Customer Records statute – Identifiers and education, employment medical and health information||As above, plus user responses to survey questions||Same as 2. A||Same as 3. A and to target sales of Information to third parties|
|C||Protected classification characteristics under California or federal law – Age, marital status, medical condition, physical or mental disability, sex and related medical conditions||Same as 1. B||Same as 2. A||Same as 3. B|
|D||Commercial information – products or services purchased, obtained, or considered, or other purchasing data||User provided customer service inquires and claim forms, from 3rd party advertisers and system collected website activity logs||Same as 2. A and to determine entitlement to rewards and amounts owed by advertisers and data purchasers||Determine amounts owed by advertisers and data buyers and performance of data campaigns|
|E||Internet or similar network activity -browsing and search history, information on a consumer’s interaction with a website, application, or advertisement||System collected activity logs and cookies||Same as 2. A and to determine (i) whether user is a repeat visitor; (ii) performance of and amounts owed to paid media suppliers; and (iii) support proof of user consent for email marketing and TCPA purposes||Same as 3. D|
|F||Inferences drawn from other personal information – profile reflecting a person’s preferences, characteristics, psychological trends and attitudes||Same as 1. B and system algorithms||Same as 2. A||None|
RIGHTS OF CALIFORNIA USERS WITH REGARD TO THEIR INFORMATION
California users have several rights regarding the collection, use, disclosure and sale of their information under the CCPA. One of these rights, notice of collection of Information, is described above; the balance of these rights are described below and include the following rights:
- Disclosure of information collected and sold
- Opt-out from the sale of Information
- Deletion of Information
- Access and portability of Information collected
Exercising Your Rights, Verification and Timing. To exercise your CCPA rights, click on the “Do Not Sell My Personal Info” link on the bottom of the Website page where we collect Information,; or email us at firstname.lastname@example.org. To prevent an unauthorized third party from accessing or making decisions regarding a user’s Information, we verify all requests to exercise these rights (a verifiable consumer request). We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, unfounded or abusive.
In general, we will verify a request by matching the identifying information supplied by the user with the Information we already have for the user. If we cannot verify the user using the foregoing method, we may request additional information which we will not retain or use for any other purpose.
For all verifiable consumer requests, we strive to respond within forty-five (45) days of receipt. If we require additional time, which can be up to ninety (90) days in the aggregate, we will provide written notice. Any disclosures we provide will cover only the 12-month period preceding the verifiable consumer request’s receipt and will be delivered electronically in a secure fashion. If, for some reason, we cannot fulfill or comply with your request, our response will explain that decision.
Removal, Amending and/or Updating Your Information
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by contacting us via e-mail at: email@example.com; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, amended or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your personal information may terminate or limit your ability to participate in the Promotions. If you wish to participate in the Promotions without any hindrance or limitation, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
We provide users with the ability to opt-out from receiving information sent via electronic mailings on or own behalf and that of our third party advertisers. Users may unsubscribe from receiving e-mail at any time by following the instructions contained at the end of every e-mailing. Unsubscribe requests can only be processed by us if you have registered with us in the first instance. If you have not registered with us and wish to opt out of receiving e-mail from a particular sender, please consult that sender’s opt out policies or contact that sender.
To opt-out from email marketing and to remove your anonymized data from programmatic advertising enabled by contacting customer service, click the “Unsubscribe” link on the bottom of every page or click here
Information sent on behalf of third party advertisers is prepared several days in advance, so users may continue to receive e-mail from us for up to ten (10) days following the unsubscribe procedures detailed above. In addition, after unsubscribing, we cannot guarantee that you will never receive another mailing from us, because we may obtain your e-mail address in the future through a different e-mail marketing program that you have opted in to. If, after that point, a user is still receiving e-mail from us, the user should contact us at: firstname.lastname@example.org.
Notwithstanding the foregoing, we may continue to contact you for purposes of communicating information relating to your request for Samples Avenue™ Offerings, including participating in any Promotions, as well as to respond to any inquiry or request made by you. To opt-out of receiving Samples Avenue™ Offerings-related, Promotions-related and/or inquiry response-related messages from us, you must cease requesting Samples Avenue™ Offerings, cease participating in the Promotions and cease submitting inquiries to us, as applicable.
In addition and as described below, residents of California (and, in certain circumstances, residents of Nevada) have the right to opt-out of the sale of their Information
ACCESSING, CORRECTING AND DELETING YOUR INFORMATION
We ask individual users to identify themselves and the Information requested to be accessed, corrected or deleted (suppressed) before processing such requests and, to the extent permitted by applicable law, we may decline to process requests that we are unable to verify, are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning Information residing on archive servers).
TO THE GREATEST EXTENT PERMISSIBLE BY LAW, IN NO EVENT SHALL WE BE LIABLE FOR ANY DAMAGES OF ANY KIND ARISING IN CONNECTION WITH THE UNAUTHORIZED ACCESS TO AND/OR MODIFICATION OF YOUR REGISTRATION DATA OR OTHER PERSONAL INFORMATION.
Transfer of Personal Information Internationally
Filing a Complaint with the Federal Trade Commission
To file a complaint regarding our privacy practices, please Click Here.