Last Updated: 3/21/2022
Note for Residents of the European Economic Area, Switzerland, and the United Kingdom: Please see Section XI below for specific details on your rights under applicable law.
- I. Introduction
- II. Definitions of Terms Used in this Policy
“CCPA” means the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. and its implementing regulations.
“Content” means all text, articles, photographs, images, video, audio, trademarks, trade names, service marks, and other brand identifiers, designs, plans, software, and all other content, information, and materials available on or through the Service or otherwise made available by us, our licensors, vendors, and/or service providers.
“Device” means any computer, tablet, mobile phone, or any other device capable of accessing the Service.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device, or household. Anonymous, de-identified, or aggregate information is not Personal Information.
“Product” means any merchandise, item, product and/or service, including without limitation Content, contests and surveys, magazines and other publications that may be featured, mentioned, reviewed, described, auctioned, given away, rented, sold, distributed, or otherwise available on or through the Service, either by us or third parties.
“Service” means each website, mobile site, application, email/text/SMS campaign, event, and/or other activity, offering, or publication provided by us.
“Service Provider” has the same meaning as set forth in the CCPA, which in general means a for-profit legal entity to whom we disclose Personal Information for processing on our behalf for a “business purpose” (as defined in the CCPA) pursuant to a written contract.
“Third-Party Business” means any third party unaffiliated with us to whom we disclose Personal Information for their own purposes.
“We,” “Us,” “Our” and "Equine Network," whether capitalized or not, means Equine Network, LLC and its affiliates and subsidiaries
“You” or “Your,” whether capitalized or not, means all those who access, visit and/or use the Service.
- III. Categories of Your Personal Information that We May Acquire
We may collect, obtain or otherwise acquire the following types of Personal Information about you, and we may make and retain inferences drawn from such information:
- Identifiers, such as your name, date of birth, signature, postal address, zip code, email address, telephone number, unique online identifier, IP address, User ID, and Device ID.
- Certain characteristics protected by applicable law, such as gender, marital status, nationality, and country of origin.
- Commercial information, such as purchase history.
- Internet or other electronic network activity information, such as website or app activity data, call logs, text messages, and emails.
- Geolocation data, such as the physical location of your Device.
- Professional or employment-related information, such as occupation, employment history and record, and resume.
- Government issued identification numbers (e.g., social security number, drivers' license number, passport number, or state identification card number).
- While we generally do not obtain biometric, financial, insurance, or medical information, we may do so when such Personal Information is necessary to offer you certain Services or where otherwise permitted by law.
- IV. How We Acquire Your Personal Information
Personal Information You Provide. We may receive Personal Information directly provided by you. For example, if you purchase a Product, or register and/or set up an account/profile or attend or participate at an event, you may provide a password and/or User ID or other payment information, as well as your contact information.
Personal Information Automatically Collected. We may automatically collect certain information, some of which may be deemed Personal Information. The information collected may include information about your Device and geographic location of you and/or your Device, as well as date/time stamp, IP address, webpages visited and actions taken on webpages, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.
Personal Information Acquired from Third Parties. We may acquire your Personal Information from third parties. For example, we may purchase or otherwise acquire Personal Information from third party consumer data suppliers/resellers, data aggregators, advertising networks, data analytics providers, internet service providers, operating systems and platforms, data brokers, business contact databases, government entities, and our parent, subsidiaries, affiliates and other related entities.
- V. How We Use Your Personal Information
Processing Your Requests. We use your Personal Information to process your requests for Content, Products, or your attendance and participation at an event.
Administering the Service. We also use and share your Personal Information for any lawful purpose in connection with administering the Service, including for customer service, system maintenance and improvement, or to improve Products that we offer by tailoring them to perceived preferences. We may use your geolocation data to show you Content (including advertising and sponsored messaging) based on geographic location.
- VI. Sharing of Your Personal Information with Third Parties.
Third Parties with Whom We May Share Your Personal Information. We may disclose your Personal Information to the following categories of third parties:
- Service Providers
- Third-Party Businesses
- Governmental and law enforcement officials
- Persons involved in an acquisition of our business or assets
Service Providers. We may share your Personal Information with Service Providers that perform services for us, but only for the purpose of and to the extent necessary to perform those services.
Third-Party Businesses. We may sell, share, and transfer Personal Information to the following types of Third-Party Businesses:
- Advertising, marketing and sponsorship clients to market their goods and services;
- Consumer data suppliers/resellers, data enrichment providers and aggregators;
- Social media and social networking services; and
- Businesses that assist us with our Products and Product recommendations.
In all such cases, your Personal Information may be used by us and by such Third-Party Business(es) for their own purposes, each pursuant to its own policies.
Affiliates. We share your Personal Information with our parent, subsidiaries, affiliates and other related entities, and our advisors, including lawyers, consultants, accountants, and others, for all purposes described in this Section VII.
Marketing Communications. We may use your Personal Information to communicate with you about new features, events or Products offered by us and Third-Party Businesses, including our advertising, marketing and sponsorship clients.
Transfer or Sale of Our Business. If Equine Network or its parent, subsidiaries, affiliates or other related entities is involved in a business transaction, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Equine Network or its parent, subsidiaries, affiliates or other related entities, we may share your Personal Information in connection with such transaction. We may also share your Personal Information to legal, financial, insurance, or other advisors in connection with such business transaction or management of all or part of our business or operations.
- VII. Cookies and Related Technologies
We may place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies, locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third-Party Businesses may independently or in conjunction use Local Device Storage in connection with the Service in a way that collects Personal Information for the purposes described in the respective privacy policies. Your Device or browser may include an option that allows you to disable Local Device Storage.
- VIII. Transfer of Your Personal Information Among Jurisdictions
Your Personal Information may be processed, transferred to, and maintained on, servers and databases located outside of the jurisdiction in which you are based and where the privacy laws may not be as protective as your jurisdiction. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.
- IX. Protection of Your Personal Information
Security Measures. We take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, Personal Information.
No Liability for Breach. Because no security system is impenetrable, we cannot guarantee the security of your Personal Information. By using the Service you agree to assume all risk in connection with your Personal Information. We are not responsible for any loss of such Personal Information or the consequences thereof.
Breach Notification. If we believe the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you subject to applicable laws and regulations governing such notifications.
- X. Notice to California Customers - Your Privacy Rights
Rights of California Residents. The CCPA grants residents of California certain rights with respect to their Personal Information.
California residents have the following rights under the CCPA:
- The right to know the ways in which we collect, use, share, disclose and otherwise process your Personal Information;
- The right to know the specific pieces of your Personal Information that we hold;
- The right to request the deletion of your Personal Information, subject to several exceptions;
- The right to opt out of the sale of your Personal Information; and
- The right not to be unlawfully discriminated against for exercising these rights.
We may take reasonable steps to verify your identity before fulfilling your request to know or delete. For example, we may seek to establish your identity by matching information that you submit alongside your request with information that we have on our records. We may also ask for supplemental information as needed to establish your identity.
Exercising Your Rights Under the CCPA. California residents, as well as Authorized agents seeking to submit requests on behalf of California residents and parents or guardians seeking to submit requests on behalf of their minors who are residents of California, may exercise the rights described below by contacting us at [email protected] or by calling us at 800-578-2607.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If you opt out of the sale of your Personal Information, we may still share your Personal Information with third parties if those transfers are not sales, such as with our Affiliates or our Service Providers.
Response Timing and Procedures
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Categories of Personal Information We Disclose
We may disclose your Personal Information to a third party for a business purpose. In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:
|Categories of Personal Information||Examples|
|Identifiers||Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.|
|Characteristics of protected classifications under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.|
|Internet or other electronic network activity information||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|Geolocation data||Physical location or movements.|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information|
|Professional or employment-related information||Current or past job history or performance evaluations.|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 USC § 232g, 34 CFR Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.|
|Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Categories of Personal Information We Sell
In the preceding 12 months, we have sold the following categories of Personal Information for a business purpose:
Identifiers, Commercial information
Do Not Track
California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how a website operator responds to “Do Not Track” (“DNT”) browser settings. DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. We do not currently take actions to respond to DNT signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a DNT standard once one is created. For information about DNT, visit All About DNT.
Shine the Light
California's “Shine the Light” law, Cal. Civil Code §1798.83, gives California customers the right to prevent our disclosure of their Personal Information to third parties for those third parties' direct marketing purposes. Businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place.
- XI. Notice to Residents of the European Economic Area (“EEA”), Switzerland and the UK
Purposes of Processing
We process your Personal Information to process your requests, to administer the Service, facilitate access by Service Providers and Third-Party Businesses, make marketing communications, facilitate health, safety and legal requests, , transfer or sell our business, and to combine data sets.
Legal Basis for Processing
We rely on the legitimate interest basis of processing for the other activities described above because processing Personal Information is necessary to provide you with our Products and to respond to your requests, our activities are reasonably expected by our customers, and those activities do not unduly and negatively affect the privacy rights of our customers. When you make a purchase, sign-up to attend or participate at an event or conference, or engage in another type of transaction with us, we may process your Personal Information to fulfill that contract. We may also process your Personal Information to comply with legal obligations to which we are subject and cooperate with regulators and enforcement bodies.
Your Personal Information may be processed in or transferred to the U.S. or elsewhere in the world. We will ensure that transfers of Personal Information to a third country or an international organization are subject to appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact the Data Protection Officer by email at [email protected]network.com or as described at the end of this section.
Erasure and Restriction of Personal Data
Unless otherwise provided for in this data protection declaration for individual cases, your Personal Information may be erased if this data is no longer necessary for the purposes for which it was collected or was in any other way processed and if there are no legal obligations that require us to keep it. We will also erase your Personal Information processed by us upon request, in accordance with Art. 17 GDPR, if the conditions described therein are met. If your Personal Information is required for other legally permissible purposes, the data will not be erased, but its processing will be restricted in accordance with Art. 18 GDPR. In the event of a restriction, the data will not be processed for other purposes. This applies, for example, to Personal Information that we must keep for commercial or tax reasons.
If you are a resident of the EEA, Switzerland or the United Kingdom, you are entitled to the following rights. Please contact our Data Protection Officer to exercise these rights by email at [email protected] or as described at the end of this section. In order to verify your identity, we may require you to provide us with Personal Information prior to accessing any records about you.
- Right to access and rectify your Personal Information. You have the right to obtain information about our processing of your Personal Information and a copy of your Personal Information that we store. You have the right to request that we update your Personal Information if it is inaccurate or incomplete.
- Right to request erasure of your Personal Information. You have the right to have your Personal Information erased from our systems if the Personal Information is no longer necessary for the purpose for which it was collected or you withdraw consent and no other legal basis for processing exists.
- Right to restrict our processing of your Personal Information. You have the right to restrict our processing if you contest the accuracy of the Personal Information we store about you, our processing is deemed unlawful and you oppose erasure of your Personal Information, or we no longer need the Personal Information for the purposes for which we collected it but we must store it to comply with our legal obligations.
- Right to portability of your Personal Information. You have the right to receive your Personal Information and to transmit it to another controller where our processing is based on consent you gave us and was carried out by automated means.
- Right to object to our processing of your Personal Information. You have the right to object to our processing where we process Personal Information based on legitimate interest.
- Right to lodge a complaint. You have the right to lodge a complaint about our collection and processing of your Personal Information to your Data Protection Authority. Contact details for Data Protection Authorities are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Equine Network, LLC
5710 Flatiron Parkway, Suite C
Boulder, CO 80301
Equine Network, LLC
5710 Flatiron Parkway, Suite C
Boulder, CO 80301
Please include your name, contact information, and the specific website, mobile site, application, and/or other service in your request.
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