US Regional Privacy Policy

This US Regional Privacy Policy (“US Notice”) supplements our Privacy Policy (together, the “Flaviar Privacy Policies”). This US Notice is for individuals residing in certain US states and is designed to help you better understand how we collect, use, and disclose your Personal Information and, depending on where you reside, how to exercise your rights under state privacy laws in the US. This US Notice applies to the residents of California, Colorado, Virginia, Utah and Connecticut and provides additional information in accordance with the California Consumer Privacy Act (as amended), the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “State Privacy Laws”). For California and Colorado residents, please see the following additional disclosures below:

Please note that the rights listed below may be limited to residents of the states listed above, and may not be available to all users. In addition, we may not be able to process your request to exercise your rights if you do not provide us with sufficient details or allow us to confirm your identity.


Your Privacy Rights
The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and may be subject to certain exceptions. Therefore, we may decline your request in certain cases as permitted by law.

  • Right to Know. You can request the following information about how we have collected and used your personal information during the last 12 months: The categories of personal information that we have collected; the categories of sources from which we collected personal information; our business or commercial purpose for collecting and/or selling personal information; the categories of third parties with which we share personal information; the categories of personal information that we “sold” (as defined in the State Privacy Laws, as applicable) or disclosed for a business purpose; and the categories of third parties to whom the personal information was sold or disclosed for a business purpose.
  • Access. You can request a copy of the personal information that we have collected about you.
  • Correction. You can ask us to correct any inaccurate personal information that we have collected about you.
  • Deletion. You can ask us to delete the personal information that we have collected about you.

Opt-out Rights
  • Opt out of certain processing for targeted advertising purposes. You can opt out of certain processing of personal information for targeted or interest-based advertising purposes, including sharing personal information for cross-contextual behavioural advertising.
  • Opt out of other “sales” of personal data. You have the right to opt out of the Sale of your personal information. “Sale” is defined broadly under California, Virginia and Connecticut Privacy Laws to include the transfer of personal information to third parties in exchange for anything of value. 


Exercising Your Rights
If you would like to exercise your right to “opt-out”, please do so here. To make any other requests under State Privacy Laws please send an email to privacy@flaviar.com.


Verification, Authorised Agents
We may need to verify your identity in order to process your right to know, access, appeal, correction, or deletion requests, and we reserve the right to confirm your identity and residency, and in our discretion, deny your request if we are unable to verify your identity or residency. As a part of this process, we may require a copy of your valid, government-issued identification. You may designate an authorised agent to make a request on your behalf. In order to designate an authorised agent to make a request on your behalf, in which case we will require valid government-issued identification for both you and the authorised agent, we may verify the authenticity of the request directly with you.


Appeals, Right of Non-Discrimination
In certain states, you may have the right to appeal our decision regarding a request related to these rights. If you wish to appeal a decision, please contact us privacy@flaviar.com. We will not discriminate against you for exercising any of your rights. This means, for example, we won’t deny you goods or services, provide you with a different level or quality of services, or charge you different prices or rates for services. If you need further assistance, or if you have a visual impairment or otherwise need an accommodation and would like to access this policy in an alternative format, please contact us at  privacy@flaviar.com. 



CALIFORNIA CONSUMER PRIVACY NOTICE


This California Consumer Privacy Notice (“California Notice”) supplements Flaviar’s US Regional Privacy Policy and applies to personal information Flaviar collects online about California consumers. This California Consumer Privacy Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).


Flaviar's Notice of Collection under CCPA
The categories of personal information Flaviar may collect and may have collected during the 12-month period are as follows:

  • Identifiers such as name, address, date of birth, telephone number and email address,
  • Other Records: such as phone number, billing address, or credit or debit card information, and any other personal information covered by Cal. Civ. Code §1798.80(e) (which may overlap with other categories listed here),
  • Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies,
  • Internet and other electronic network activity information such as your interaction with our website and applications,
  • Geolocation data: your general location provided through location-enabled services such as WiFi and GPS,
  • Inferences drawn from the information identified above reflecting the consumer's preferences. 


The Sources and Purposes for Our Collection
We collect the categories of personal information from the sources described in in our Privacy Policy, which includes collecting information directly from you, your devices, and our partners. The sources of this data include you, consumers yourself, gift senders (for gift recipients), third party platforms through which consumers choose to login, advertising networks, service providers (including internet service providers), social networks, government entities or other public records, fraud detection service providers, information vendors, and marketing and business partners.


Sale or Sharing of Personal Information
Flaviar does not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information through automated technologies on our Website for targeted advertising purposes. This kind of sharing may be considered a “sale” under California law, and you have a right to opt out of it.

We may sell or share (and may have sold or shared  in the preceding 12 months) personal information for the following business or commercial purpose(s):

  • Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance applicable legal standards.
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Performing services, including maintaining or servicing accounts, providing customer service, facilitating orders and transactions, verifying customer information, Advertising and marketing and analytics.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality and safety of the service, and to improve, upgrade, or enhance the service.

You can opt out of allowing us to share your data for purposes of cross-context behavioural advertising by clicking the “Do Not Sell or Share My Personal Info” link at the footer of our homepage or through your account privacy settings. We do not knowingly sell or share the personal information of minors younger than 16.


Disclosure of Personal Information for a Business Purpose
The category or categories of consumers' personal information Flaviar has disclosed for a business purpose in the preceding 12 months are as follows (please note that not every one of the following categories may apply to your information):

  • Identifiers such as name, address, telephone number and email address,
  • Other Records such as phone number, billing address, or credit or debit card information, and any other personal information covered by Cal. Civ. Code §1798.80(e),
  • Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Internet and other electronic network activity information such as your interaction with our website and applications,
  • Geolocation data such as  your general location provided through location-enabled services such as WiFi and GPS,
  • Inferences drawn from the information identified above reflecting the consumer's preferences.

California Consumer Privacy Rights
Please see the “Your Privacy Rights,” “Opt-out Rights,” and “Exercising Your Rights” of our US Regional Privacy Policy for information about your privacy rights and how to exercise them.


“Shine the Light" Law
California residents are entitled to ask for a notice describing what categories of personal information Flaviar share with third parties for their own direct marketing purposes. Any such requests should be sent to privacy@flaviar.com. In your request, please include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

 

COLORADO PRIVACY NOTICE


This Colorado Privacy Notice (“Colorado Notice”) supplements this Flaviar’s US Regional Privacy Notice and applies to personal information Flaviar collects online about Colorado consumers. We adopt this Supplemental Notice to comply with the Colorado Privacy Act (the “CPA”). This Colorado Notice uses certain terms that have the meanings given to them in the CPA.


Collection and Use of Personal Information
Please see Sections Types of Information We Collect and How We Use this Information of the Privacy Policy for information about the categories of personal information we collect and the purposes for which we use the information. We do not knowingly process personal information from children under the age of 13. We do not knowingly process “sensitive data” as that term is defined under the CPA.


Sharing of Personal Information
We share your information with our service providers or other third parties where necessary to perform the Services, comply with our legal obligations, or for purposes set out in this Privacy Policy. Your personal information, including account details, payment information, customer support information, browser/device information, and service usage information, among others, may be shared with our service providers or other third parties. Examples of the categories of third parties with whom we share personal information include vendors selling on our platform, professional services such as auditors, our marketing and business partners, online advertising services, and data analytics providers. Please be aware that not all of these categories may be relevant to your personal information.


Sales and Targeted Advertising
We do not sell your personal information in exchange for monetary compensation. We may share your personal information by allowing certain third parties (such as online advertising services) to collect personal information via automated technologies on our Website for targeted advertising purposes. You have the right to opt out of these types of disclosures of your information. We may “sell” (as defined by statute) or share for cross-context behavioural advertising purposes the following categories of personal information about you to online advertising services or networks:

  • Identifiers: information that identifies you, such as your email address or unique personal identifiers (such as a device identifier and/or IP address).
  • Commercial Information: information such as purchases or products sold.
  • Online and Network Activity: information such as interactions with our Services (including what led you to our Services such as traffic-related information); device type, operating system and version, browser type and settings, and cookie-related data (e.g., cookie ID).
  • Inferences: inferences based on personal information about you, including your interests, preferences, and favourites; inferred information about your demographic category used to create marketing segments or profiles.


Colorado Consumer Privacy Rights
Please see sections “Your Privacy Rights,” “Opt-out Rights,” and “Exercising Your Rights” of our US Regional Privacy Policy for information about your privacy rights and how to exercise them.