Last Updated: 21stAugust 2018
We reserve the right to modify this Policy at any time, so please review it regularly for any changes. If we make material changes to this Policy, we will notify you on the top of this page that it has been updated, and reflect the date it was last updated.
Please contact our Privacy Compliance and Data Protection Officer (“Privacy Officer”) if you have any questions or comments about this Policy or our privacy practices, at mail@IDstewardship.com. You can also send inquiries to:
Charlie Rose LLC
5790 SW 60thStreet
Miami, FL 33143
CHILDREN UNDER 13
Our Sites are intended for a general adult audience and not targeted or intended for children under the age of 13. Accordingly, we do not knowingly or intentionally collect personal information from children. If we learn that we have collectedor received personal information from a child under 13, we will delete that information. If you believe that a child has provided us with personal information, please contact our Privacy Officer at mail@IDstewardship.com.
INFORMATION WE GATHER AND USE
Charlie Rose collects certain user information to help us provide you a better service. We only collect information about you if we have a reason to do so. For example, we collect information directly from you, like when you create an account or make a purchase, and automatically as you interact through the Sites, including your computer’s internet protocol address.
Information You Give Us: The term “Personal information”means information that is used to identify you as an individual person. It may include first and last name, billing and shipping address, telephone number, credit card information, and/or email address. We collect Personal Information directly from you when you do any of the following:
- Account Information. We collect information such as your name and email address when you: sign up for a free account or for a paid Membership Subscription, subscribe to our newsletter, and/or participate in any rewards program we may offer. We may collect passwords, password hints, and similar security information used for authentication and account access.
- Transaction and Billing Information. We offer paid Membership Subscription services. When you sign up for these services, you will provide additional personal and payment information that is required to process the transaction, such as your name, credit card information, and contact information.Payment is processed through third-party gateway providers (g.,Stripe). These gateway providers securely transfer your credit card information to our payment vendors, which is never stored on any of our servers.All direct payment gateways adhere to PCI-DSS standards that are managed by the PCI Security Standards Council. These standards and requirements help safeguard the secure handling of credit card information by us and its service providers.Third party service providers, such as payment gateways, and credit card companies, adhere to their own privacy policies regarding the information we provide to them with respect to your purchase. We recommend that you read the privacy policies of these providers (e.g., Stripe) so that you can understand how your information is handled by them.
- Communications to Us. You may provide us information when you respond to surveys, enter a contest, or communicate to us via email or other sources regarding our Sites, products, and/or services, including reporting any problems.
- Other Information. We also collect information about you through the transactions you carry out through our Sites and in the fulfillment of our services, including your preferences, special requests, and information about the devices used to complete the transaction.
- Public Posts. If you publicly post, provide, or share information about yourself on any public areas of our Sites that we may have, such as product reviews, social media, or blogs, then it may be accessible to the general public, and you do so at your own risk. We cannot control the actions of other users of the Sites or what they may do with that information. Please see our Terms of Service for more information.
Information Collected Automatically: When you browse and interact with our Sites, we may automatically collect information that does not personally identify you but that is about you and/or your equipment, through the use of data collection technology (“Automated Information.”) We use this information to help us learn about your browser and operating system, to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking), to provide targeted ads, and to provide you with a personalized experience. Specifically, we collect the following information automatically:
- Log and Usage Information. We collect information that is typical of most web browsers and mobile devices such as unique devise identifiers, language preferences, information about your computer’s internet protocol (IP) address, your location based upon your IP address, browser type, the date and time of access, operating system, mobile network information, internet connection, domain name, the equipment you used to access our Sites, information about your device (screen size, mobile device manufacturer), gender, search terms, links on the Sites you have clicked, and specific pages you have browsed and time spent on those pages.
- Information from Cookies and Other Technologies. We use various technologies to collect information, such as cookies and web beacons.A cookie is a small file placed on the hard drive of your computer. Most browsers automatically accept cookies. Cookies do not give us access to your computer or identify you. For more information about how to control cookies, click here. Web beacons are small electronic files (also known as clear gifs, pixel tags, and single-pixel gifs) that convey information when a user visits the pages of our Sites and open an email. Cookies and web beacons permit us, for example, to count users who have visited those pages or identify who has opened an email, and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity), and to deliver targeted ads.
Throughout this Policy, we will refer to your Personal Information and Automated Information collectively as “Personal Data.”
HOW WE USE YOUR INFORMATION
We will never share or sell your Personal Information that specifically identifies you or information that is specifically related to your use of our Sites, other than for the purpose of administering our products and/or services, as detailed below.
Purpose for Using Information. We use Personal Data for the following purposes:
- In the Operation of our Business. We use your Personal Data to maintain and administer your account, and to fulfill your paid Membership Subscription and/or other purchases.
- To Personalize Your Online Experience. We use your Personal Data to store information about your preferences, to recognize you when you return, and to facilitate and personalize your online experience.
- To Communicate with You. We may use your Personal Data to notify you about changes or updates to our Sites, your account, and/or any of our products or services.
- To Send You Marketing Materials. We may use your Personal Data to send you emails about content, offers, and promotions that might be of interest to you, or to solicit your feedback or ask for you to respond to a survey. You can opt-out of our marketing emails at any time, as described below.
- To Post Testimonials. With your consent and approval, we may use your Personal Data to post testimonials that you provide us. You may revoke your consent at any time.
- For Site Analysis.We use your Personal Data to help us analyze our Sites, products, and/or services, and other market research, and to estimate audience size and usage patterns.
- For Targeted Advertising. We use your Personal Data to provide you with targeted advertising based on your interests and/or location and to measure its effectiveness.
- To Protect our Sites. We may use your Personal Data to monitor, prevent, and/or protect against problems with our Sites, and detect and/or prevent fraudulent transactions and/or illegal activity.
- Legal Obligations. We use your Personal Data to carry out our obligations arising from contracts entered into between us (g.,billing), and/or to respond to legal requests (e.g.,subpoena).
- Aggregated Data. We may also aggregate the information we collect about a user which is maintained in personally identifiable form in combination with the other identifiers described herein (g., device identifier or geo location data). This information will be completely anonymous and could never be tracked to you.
- For any Other Lawful Purpose.
Purpose for Processing Information.We process Personal Data for any one or more of the following purposes, depending on the context:
- Performance of a Contract. Processing your Personal Data is necessary to perform a contract with you, including our Terms of Service, any purchase agreement, or other agreements with you, or is necessary to administer your account.
- Legal Obligation. Processing your Personal Data may be necessary to comply with legal obligations, such as complying with tax or other government regulations, or responding to court orders or subpoenas.
- Legitimate Interests.Processing your Personal Data is necessary when we have a legitimate interest in using your information, such as: in the operation and promotion of our business, to provide and update our Sites, to improve our Sites so that we can offer you a better, more personalized experience, to monitor, safeguard and protect our Sites, to communicate with you, to analyze our Sites and measure the effectiveness of our marketing, and to protect against fraud, spam and abuse.
- Safety and Security.Processing your Personal Data is necessary in order to protect the vital interests of those of another person.
- We process your Personal Data when you consent. You can withdraw your consent at any time as described below.
SHARING AND KEEPING YOUR INFORMATION
We share your Personal Data with third party service providers and contractors who complete transactions or perform services on our behalf or for your benefit, including payment processing, marketing, analytics, and verifying data such as mailing addresses. We do not sell your private Personal Information. We will retain the Personal Data that you provide for so long as is necessary to fulfill its purpose and/or we will retain and use your Personal Data to the extent necessary to comply with legal obligations, resolve disputes, and enforce agreements and policies.
We share your information as set forth below:
- Legal and Safety Reasons. We may disclose your Personal Data for legal, business or safety reasons. For example, disclosure may be necessary to enforce our legal rights against you. We may also disclose such information to third parties in connection with claims, disputes or litigation, or to comply with any court order, law, or legal process, including to respond to any government or regulatory request. We may disclose Personal Data for auditing, compliance, and corporate governance functions. Disclosure may also be made to prevent fraud or other illegal activity against Charlie Rose and/or others.
- Affiliates, Subsidiaries, Assigns, Employees, and Independent Contractors. We may disclose your Personal Data to our affiliates, subsidiaries, assigns, employees and/or independent contractors who need to know the information to help us provide the Sites, services and/or products to you, and all of whom must adhere by this Policy.
- Business Transfer. Your Personal Data may also be disclosed as a result of a business transfer. Disclosure may be made to a buyer or other successor in the event of a merger, consolidation, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Charlie Rose’s stock or assets, or other corporate change, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Charlie Rose about our Sites’ users is among the assets transferred, and/or as part of any due diligence process.
- Third Party Vendors and Service Providers. We may share your Personal Data with third party vendors and service providers to help us provide our Sites, products, and services to you. Examples include payment providers that process your credit and debit card information, fraud prevention services that analyze fraudulent payment transactions, postal and email delivery services that help us communicate with you, website hosting services, those that help with our marketing efforts and campaigns, and analytic tool providers, which track and and analyze data.
- With Your Consent. We may share your Personal Data with your consent or at your direction (g.,testimonials or any information you publicly share by posting content).
- Third Party Advertisers. We may use third-party advertising companies to post ads when you visit the Sites. These advertising companies may use Personal Data information collected about you and contained in cookies, web beacons or other tracking technologies in order to provide advertisements about goods and services that may interest you.
- Aggregated or De-Identified Information. We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonable be used to identify you. For example, we may share information about how many users visited our Sites.
YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
Under the EU’S General Data Protection Regulation (GPDR), European Union residents have certain data protection rights. To the extent that the GDPR governs the Sites and/or your use, in certain situations, EU residents have the following rights regarding their “personal information” (as defined under the GDPR) that we collect and use about you:
- To access your information;
- To update, correct or delete your information;
- To object to our processing of your information;
- To request that we restrict the processing of your information;
- To be given a portable copy of your information (g.,in a machine readable and/or usable format);
- To withdraw your consent at any time where Charlie Rose relied on your consent to process your information; and
- To complain to the Data Protection governmental authority about our collection, use and/or procession of your information.
CHOICES – ACCESSING, UPDATING, OPTING-OUT
Account Information. You may, at any time, access, review, and/or modify your information by logging into the Website, and visiting your account profile page. You may also delete or terminate your account. You may also contact us directly to make changes at mail@IDstewardship.com.We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your account or terminate any paid Membership Subscription services, we will deactivate and delete your account and information, except as is necessary to prevent fraud, troubleshoot, assist with investigations, and/or enforce any contracts between us. Please see our Terms of Service for more information about terminating paid Membership Subscription services.
Email Advertising. You may opt-out of email marketing anytime by unsubscribing from our emails, or by contacting us directly at mail@IDstewardship.com. We may, however, continue to send you emails necessary for the administration and use of your account and/or for necessary updates.
Public Posts. In most circumstances, you can delete your posts in the public areas of the Sites. However, copies of posts may remain viewable in cached and archived pages, or might have been copied or stored by other Website users, which we have no control over.
Cookies.You may set your browser to block cookies. However, if you select this setting you may be unable to access certain parts of our Website.Cookies do not give us access to your computer or identify you. For more information about how to control cookies, click here.
We may also use third party advertising services including Google AdWords, Facebook and Instagram. Using data technology like cookies and web beacons, these services may collect Personal Data about your activities over time and across different websites, and may provide us with that information. They may also use this information to provide you with targeted (interest based) ads on websites that you visit after visiting our websites.
If you prefer, you can opt out of seeing these ads. For more information on opting out of Google Ads, click here. For more information on opting out of Facebook ads, click here. For more information about Instagram ads,click here. For more information about targeted ads, visit the Network Advertising Initiative (NAI) website here. You can also learn about opting out of interested based ads at the NAI here. For more information about opting out of ads targeted to your mobile device, click here. If you are accessing the Sites from Canada, please visit the DAAC opt-out page here.
Opting out of interest-based ads does not mean you will stop seeing ads. Rather, the ads will not be targeted to you based upon your interests. Since these opt-outs are cookie based, you will need to repeat the opt-out procedures if you clear your cookies at any time.
We do not control these third parties’ tracking technologies, how they may be used, or the information they collect. This Policy does not govern the collection of information by those third parties. We are not responsible for the privacy policies of these third parties. Please refer to the privacy policies of those companies to determine how they collect and use your information.
Do Not Track Disclosure. Do Not Track (DNT) is a privacy setting in your web browser that when turned on, disables a web application from tracking a user. See All About Do Not Track. At this time there are no universal standards on recognizing DNT signals, and therefore, we do not respond to “Do Not Track” signals from your browser.
INTERACTING WITH SOCIAL MEDIA ON OUR WEBSITE
We provide links to our social media platforms on our Website. This Policy governs any interaction you have with these social media sites through our Website.
LINKS TO THIRD PARTY SITES
Our Sites may provide links to third party websites. Charlie Rose is not responsible for the content, policies, or practices of those third party websites. We suggest you review the privacy policies of those third party websites for information about how they may collect your information.
YOUR CALIFORNIA PRIVACY RIGHTS
Subject to certain limitations, California residents are entitled to obtain, once a year, what information, if any, we shared with third parties for their direct marketing purposes (Cal. Civil Code Section § 1798.83). Upon request, Charlie Rose will provide you with a list of the categories of personal information (as defined in the statute) disclosed to third parties, and the names and addresses of those third parties that received personal information during the preceding year. To make such a request, please send an email to: our Privacy Officer at mail@IDstewardship.com.
SECURITY OF YOUR INFORMATION
Charlie Rose takes the protection of your data seriously. We take reasonable measures and use generally accepted industry security standards to help prevent unauthorized access to your information. However, no method of transmitting information over the Internet or storing information is one hundred percent secure. Therefore, we cannot guarantee the absolute security of that information.
Your Personal Data may be transferred and/or maintained on servers located outside of your state, province and/or country where the privacy laws may not be as restrictive as they are in your jurisdiction. If you are located outside of the United States and provide your Personal Data to us, we may transfer that information to the United States and process it there.