Sole Proprietor Podolsky D.M.
Effective May 25, 2018
1. Who we are
- Who we are
- How this Policy applies
- Who is the Data Controller?
- Data you provide to us
- How we collect information
- How we use this information
- How we share your information with third parties
- Your controls and choices
- European Economic Area residents: Legal basis for use of your information & controls and choices
- How we protect your information and data retention
- Data transfers, storage, and processing globally
- Privacy Shield
- Children's privacy
- Rights of California residents
- Contact us
, including on a mobile device, mobile application and related services (the "Service" or the "Services") or any other service to which this policy is linked. 3. Who is the Data Controller?
Sole Proprietor Podolsky D.M. is the "data controller" of personal data collected by all of Luckygrass, and Sole Proprietor Podolsky D.M. is responsible for deciding how personal data is collected, used, and disclosed. Campaign Owners may also be data controllers of certain data you provide to Campaign Owners when you make a Contribution to a Campaign or through any other Services.
We collect information you provide directly to us, information from third parties, and information that we collect through automated means. For example, we collect:
Your personal information when you place an order, write and email, contact us via chat form, which is built in the website.
Transaction information you provide when you request information, contact Luckygrass, place and pay for an order.
Information sent directly to another User, post, or similar functionality, where we are permitted by applicable law to collect this information.
Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices.
Location information, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this information.
Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences.
Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address.
You may decline to provide us with your information. However, this will limit your ability to order uniform or use our Services. You may contact us by providing only an email address. You may review, change or remove your information through your account settings. 5. How we collect information
We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to User surveys, or otherwise interact with us online or offline.
We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.
Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:
To enable us to provide you with our Services, and to improve and promote our Services;
Communicate with you about your orders and send you information or request feedback about features on our sites and products or changes to our policies.
Send you offers and promotions for our products and services or third-party products and services.
Personalize content and experiences.
Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications.
Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including by performing User market research and using analytics tools.
Detect, investigate and prevent activities that may violate our policies or be illegal.
We may aggregate and/or anonymize any information collected through the Service so that such information can no longer be linked to you or your device ("Aggregate/Anonymous Information"). We may use Aggregate/Anonymous Information for any purpose and share such data with any third parties, including advertisers. 7. How we share your information with third parties
We will share your information in the following ways:
Please note that once we share your personal information with a Campaign Owner, the information received by the Campaign Owner is controlled by that company and becomes subject to the Campaign Owner's privacy practices.
When you allow us to share your personal information with another company, such as:
Electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services; and
Directing us to share your personal information with third-party sites or platforms, such as social networking sites.
Please note that once we share your personal information with another company, the information received by the other company is controlled by that company and becomes subject to the other company's privacy practices.
When companies perform services on our behalf, like marketing and advertising, and customer service; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law; and
When we share your personal information with your consent, including when you post personal information on public forums or blogs accessible to third parties. 8. Your controls and choices
The laws in some jurisdictions requires us to provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. To the extent those laws apply to you, your controls and choices may include:
Updating, and deleting your registration account;
Choosing or changing your choices for subscriptions, newsletters, and alerts;
Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you;
Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services;
Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers (by visiting the Digital Advertising Alliance);
Controlling whether you want us to access location information, such as by controlling or disabling location services in your mobile device's settings menu;
Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by re-setting your device's advertising identifier and/or opting out of interest based ads;
Requesting removal of your personal information from a public forum on one of our sites or application.
You may exercise these controls and choices in various ways, including contacting Customer Support, following instructions provided in communications sent to you, or by using your device or other available settings (for example, by re-setting your device's advertising identifier and/or opting out of interest based ads). You can opt out of interest based ads by visiting the Digital Advertising Alliance or using the opt-out mechanism in the "Interest Based Ads" link in the footer of the site you are visiting.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our Services may not be able to take account of your interests and preferences. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact us. 9. European Economic Area residents: Legal bases for use of your information & controls and choices
The laws in the European Economic Area and some other jurisdictions require us to provide Users, to the extent those laws apply to such Users, with the following information:
Legal grounds for use and disclosure of personal information
On the basis of implied or express consent, such as to send you certain information, including marketing communications, to share your information with partners when you have requested we do that, or to collect and process your information for research purposes if you have Contributed to a Campaign, or otherwise agreed; or
For our legitimate interests or the legitimate interests of others such as to ensure the security of our Sites, operate and improve our business and our Sites, respond to your questions, engage in certain marketing, make and receive payments, comply with our legal obligations, prevent fraud, conduct analysis, enforce our Terms, engage in a business change (e.g., sale, merger), to know User to whom we are providing the Service, and to create anonymous data.
To protect the vital interests of the individual or others. For example, we may collect or share personal data to help resolve an urgent medical situation. 10. Controls and choices
In addition, Users in the European Economic Area and some other jurisdictions outside the United States have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them (including, in some cases, in portable form), and to obtain its correction, update, amendment or deletion in appropriate circumstances. They may also object to our uses or disclosures of personal data, to request a restriction on its processing, or withdraw any consent, though such actions typically will not have retroactive effect. They also will not affect our ability to continue processing data in lawful ways (for example, if you opt out of the use of your telephone number for direct marketing, we might still decide to contact you by phone regarding potential fraud on your account).
Users in the European Economic Area have the right to opt-out of all of our processing of their personal data for direct marketing purposes. To exercise this right, they may contact us.
The rights and options described above are subject to limitations and exceptions under applicable law. In situations in which we process personal data on behalf of our User, we may refer the request to the relevant User and cooperate with their handling of the request, subject to any special contractual arrangement with that User.
In addition to these rights, Users in the European Economic Area have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern. 11. How we protect your information and data retention
To bring you the Services, we operate globally. Luckygrass complies with the EU-US and Swiss-US Privacy Shield principles (the "Principles") regarding the collection, use, sharing, and retention of personal information from the European Union and Switzerland, as described in our EU-US Privacy Shield certification and Swiss-US Privacy Shield certification. If you have a Privacy Shield-related complaint, please contact us firstname.lastname@example.org. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, alternatively through the independent dispute resolution body JAMS, and under certain conditions, through the Privacy Shield arbitration process.
Residents of the European Union or Switzerland may elect to arbitrate unresolved complaints but prior to initiating such arbitration, you must: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from our designated independent recourse mechanism above; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department of Commerce time to attempt to resolve the issue. Each party shall be responsible for its own attorney's fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the individual.
Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal information from the EU or Switzerland to third parties outside the EU and Switzerland. As required under the principles, when we receive information under the Privacy Shield and then transfer it to a third-party service provider acting on our behalf, Luckygrass has certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage. Learn more about the EU-US Privacy Shield and Swiss-US Privacy Shield.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request
. 14. Children's privacy
People under 18 (or the legal age in your jurisdiction) are not permitted to use Luckygrass on their own. Luckygrass does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services. If you believe that a child has provided us with personal information, please contact us at email@example.com. If we become aware that a child under age 13 has provided us with personally identifiable information, we'll delete it.