Effective July 1, 2020
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, combining, disclosing and transferring information within our organization or among our affiliates.
In the course of using the Service, we may ask you for certain information that can be used to contact or identify you, including, but not limited to, your name, email address, phone number and credit card number and other billing information (“Personal Information”).
We collect Personal Information in connection with your registration with the Service and use of the Service. If you decide to register, you must provide a username and you can choose what other information you provide as part of your profile. Other users may see your username on the Service.
During the registration process or in connection with listing an item for sale through the Service, you may also link your SARTOR account with certain third-party social networking sites (“SNS”), including, but not limited to, Instagram and Twitter. If you decide to link your SNS account with your SARTOR account, we will obtain certain information you have provided to the SNS (such as the name you provided the SNS, profile picture, email address and other information you make publicly available via the applicable SNS) from the account you have with such SNS and import that information to your SARTOR account (“Account”); the information we obtain may depend on the privacy settings you have with the SNS. The information an SNS has about you is obtained by the SNS independent of the Service. Other services, including the SNS, follow different rules regarding the use or disclosure of the information you submit to them. We encourage you to read the privacy policies or statements of the other services you use.
Our Apps may collect information about the precise location of your mobile device if you enable location services and grant permission. We may also use your IP address to derive your device's general location.
We may combine the information we receive from you with information (including Personal Information) we obtain from other sources. We may aggregate your information with information collected from other SARTOR Users to provide you with a better experience, to improve the quality and value of the Service, and to analyze and understand how the Service is used.
We may use the information we collect for the following purposes:
To provide the Service, complete your transactions, and respond to your inquiries;
To contact you with SARTOR newsletters, email updates, marketing or promotional materials and other information that may be of interest to you;
To maintain, operate, monitor, customize, improve, and analyze use of the Service;
To comply with law enforcement and maintain the security of the Service; or
As otherwise disclosed at the time of collection or use.
If you decide at any time that you no longer wish to receive marketing communications from us, please click “Unsubscribe” at the bottom of any marketing email you receive from us (no login required).
We may share your information with third parties as described in this section.
Profile Information. As noted above, when you create a profile on the Service, other registered users may be able to see the information that you include in your profile. You should exercise care in deciding what information to provide.
Affiliates. We may share information with our affiliates, including Flight Club New York LLC, which will handle the information under their own respective privacy policies. Where required by law, we will give you a choice about this sharing.
Service Providers. We may employ third-party companies and individuals to facilitate the Service, to provide the Service on our behalf, to perform Service-related functions (for example, payment processing services, maintenance services, database management, marketing, security and fraud purposes, web or advertising analytics, and improvement of the Service’s features) or to assist us in analyzing how the Service is used.
Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with applicable laws and regulations. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of SARTOR or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, harmful, unethical or legally actionable activity.
Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your information, in connection with a potential or actual merger, acquisition, reorganization or sale of some or all of our assets or in the event of bankruptcy.
With Consent. We may share your information with your consent or as otherwise disclosed at the time of data collection or sharing.
Aggregated and Deidentified Information. We may share aggregated or deidentified information without limitation. This includes sharing the types of technical information that we collect as described above (including information that identifies a device), to the extent permitted by law.
DIGITAL ADVERTISING AND ANALYTICS
We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Service and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.
You can visit www.aboutads.info or www.networkadvertising.org/managing/opt_out.asp to learn more about interest-based advertising and how to opt-out of this advertising on your browser by companies participating in industry self-regulatory programs.
To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by companies that participate in the Digital Advertising Alliance’s AppChoices tool, please download the version of AppChoices for your device, available at the links below:
DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon
Note that choosing to opt out will not stop advertising from appearing in your browser. It may make the ads you see less relevant to your interests. Advertising Providers may continue to collect data for other purposes, including analytics and other operational purposes.
CHANGING OR DELETING YOUR INFORMATION
If you have registered with the Service, you may review, update, correct or delete the information in your profile through your profile page. If you would like us to delete your record in our system, please contact us at firstname.lastname@example.org with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
We use appropriate security measures to protect against the loss, misuse or alteration of your Personal Information. To make sure your Internet browser is using the latest security features, you may want to download the most recent version of it, which should have full SSL (Secure Socket Layer) support.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD
EEA and Swiss individuals have the right to access the personal data (as that term is defined in the Privacy Shield Framework) that we maintain about you, and you may be able to correct or amend that information if it is inaccurate or has been processed in violation of the Privacy Shield Principles, to the extent allowed by law. To exercise this right, please email email@example.com.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EEA and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at firstname.lastname@example.org. For any complaints that cannot be resolved with us directly, we commit to cooperate with EEA data protection authorities and the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by EEA data protection authorities and/or the Swiss Federal Data Protection and Information Commissioner with regard to data transferred from the EEA and Switzerland, as applicable. A binding arbitration option may also be made available to you in order to address Privacy Shield complaints not resolved by any other means.
Retention of personal information of EEA individuals will be handled in accordance with our data retention policy. Where we process personal data of EEA individuals as a data controller, such individuals: (i) may have the right to request access to and rectification or erasure of personal information by emailing email@example.com; (ii) may restrict the processing of personal information, object to processing, and/or exercise the right of data portability; and (iii) may have certain rights to withdraw consent without affecting the lawfulness of processing and the right to lodge a complaint with a supervisory authority. For any requests or information regarding the rights set out above, please contact us by emailing us at firstname.lastname@example.org.
LINKS TO OTHER SITES
The Service may contain links to other websites and apps. If you click on a third-party link, you will be directed to that third party’s website or app. The fact that we link to a website or app is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites or apps. These other websites and apps may place their own cookies or other files on your computer, collect data, or solicit information from you. Other sites follow different rules regarding the use or disclosure of the information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
The Service may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share Personal Information or you otherwise interact with these features on the Service, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with us and the general public. Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use on third-party websites or apps.
OUR POLICY TOWARDS CHILDREN
The Service is not directed to children under the age of 16. We do not knowingly collect Personal Information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us here. If we become aware that a child under 16 has provided us with Personal Information, we will delete such information from our files.
NEVADA PRIVACY RIGHTS
Under Nevada law, Nevada residents may submit a request directing us not to make certain sales of personal information we maintain about them, if we engage in such sales in the future. To exercise this right, please contact us by email at email@example.com.
CALIFORNIA PRIVACY RIGHTS
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by contacting firstname.lastname@example.org for an alternative format of this notice.
Personal Information We Collect and Disclose for a Business Purpose. We collect the categories of personal information about California consumers identified below.
A. Personal and online identifiers (such as first and last name, email address, or unique online identifiers);
B. Categories of information described in Section 1798.80(e) of the California Civil Code (such as phone number, bank account number, credit card number, or debit card number);
C. Characteristics of protected classifications under California or federal law (such as age);
D. Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered);
E. Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
F. Geolocation information; and
G. Inferences drawn from the above information about your predicted characteristics and preferences.
In the past 12 months, we have disclosed all of the categories of California consumers’ personal information described above to third parties for business or commercial purposes, as described in more detail below under “Recipients of California Personal Information”.
Categories of Sources. We collect the personal information described above under “Personal Information We Collect and Disclose for a Business Purpose” in categories A, B, E, F, and G from the following sources:
Consumers, including through activity on our website and mobile application;
Service providers; and
Affiliates not under the SARTOR brand.
We collect the personal information described above under “Personal Information We Collect and Disclose for a Business Purpose” in categories C and D from the following source:
Our commercial purposes, which include:
Our business purposes as identified in the CCPA, which include:
Auditing related to our interactions with you;
Detecting and protecting against security incidents, fraud, and illegal activity;
Debugging to identify and repair errors that impair existing intended functionality;
For the performance of services on our behalf, such as the provision of customer service, the processing or fulfillment of orders and transactions, the verification of customer information, the processing of payments, the provision of advertising, marketing or analytic services, and the provision of other similar services on our behalf;
Internal research for technological improvement;
Activities to maintain and improve our services;
Short-term, transient uses; and
- Other operational purposes.
We may also use and disclose the personal information we collect to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Recipients of California Personal Information. We do not sell the personal information we collect to third parties.
We disclose the categories of personal information described above to the categories of third parties listed below for business purposes:
Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information.
The right to request that we delete the personal information we have collected from you or maintain about you.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the above rights, please contact us by email at CCPA@sartor.io with an explanation of the rights you wish to exercise and submit the required verifying information, as further described below.
You may also exercise your right to request that we delete the personal information we have collected from you or maintain about you by sending a letter to us by mail that explains you would like to exercise this right and that includes your name. You can send this letter to us at the following address: SARTOR, Attn: SARTOR CCPA, 3433 W Exposition Pl, Los Angeles, CA 90018.
In certain circumstances permitted by the CCPA or because of a conflict with applicable law, we may deny all or part of a request to exercise the above rights, in which case we will notify you of such denial and the reasons for such denial.
Verification Process and Required Information. At a minimum, we will ask you for your name, email address, and telephone number. Note that we may need to request additional information from you to verify your identity or process your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will use the personal information you provide us in connection with your exercise of the above rights only to review and comply with your request.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by designating such agent in writing or through a power of attorney. Before we accept a CCPA request from an agent, we will require the agent to provide us with proof that you have authorized the agent to make the CCPA request on your behalf, and we may need you to verify your identity directly with us.
Minors’ Right to Opt In. We do not sell the personal information of minors under 16 years of age.