Privacy Policy | Textedly

New Privacy Policy

Last Updated: July 1, 2024

Introduction

Welcome! Inunity, LLC and its subsidiaries, including Textedly, Texting Base, Textline, and Mozeo (the “Company” or "we," "our" or " us") are committed to protecting your privacy.

This Privacy Policy governs how we collect, store, and use your personal data (as defined below), as well as other data and information arising out of and/or relating to you and/or your use of our Services – which include your use of www.textedly.com, www.textingbase.com, www.textline.com, and www.mozeo.com (the “Sites”), and any other technologies, features, mobile applications, and content we offer (collectively, the “Services”).

We are a business-to-business service provider whereby we provide notification and messaging services that allows paid subscribers (each a "Client" and collectively our "Clients") to contact and send messages and information to their user database ("users") through mobile text messaging services and other mobile communication systems. Our Privacy Policy primarily explains our data collection practices when collecting, storing and or using data on behalf of our Clients as a service provider, including the content of text messages. If you are a consumer who received a message delivered by us because one of our Clients uses our Site and you wish to opt-out from receiving additional messages, please visit Your Privacy Choices (Section 10 of this Privacy Policy) below.

This Privacy Policy does not apply to information regulated by federal law such as the Health Insurance Portability and Accountability Act and similar federal and state laws, including the privacy and security protections of those laws (collectively, “protected health information” or “PHI”). With respect to any PHI that Textline may receive from covered entities, Textline will comply with its obligations under HIPAA as a business associate and we encourage you to visit the Privacy Policy or Notice of Privacy Practices of your employer.

This Privacy Policy does not apply to third-party websites, products, or services, even if they may link to our Sites or our Sites may link to them. We recommend you review the privacy practices of those third parties before accessing third party websites and sharing any personal data.

In addition, please review the Site's Terms of Service, which governs your use of the Site. To keep things simple, we use the same capitalized terms as those set forth in the Terms of Use, and their respective definitions, apply equally to this Privacy Policy.

To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

Linkable Table of Contents

It is important that you read and understand the entire Privacy Policy before using the Site. This Privacy Policy is provided in a layered format. You can jump to a specific section by clicking on the section below.

1. Personal Data We May Collect, Use and Disclose

We collect, use, and disclose information that may be used to uniquely identify you in various ways in accordance with applicable law.

2. Sources of Personal Data

We may collect personal data from various sources.

3. Disclosure of Personal Data

We may disclose your personal data to certain third parties, such as our service providers and advertising partners.

4. Links to Other Sites

Our Site may contain links to other websites that are not operated by us and are not subject to this Privacy Policy.

5. Cookies and Tracking Technologies

We collect information about your use of the Service through cookies and other tracking technologies.

6. How We Protect Your Information

We use reasonable and appropriate technical and organizational measures to protect your personal data.

7. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy.

8. International Transfers of Your Personal Data

Your personal data may be transferred to the U.S. and other countries.

9. Children's Privacy

Our Services are not intended for use by children under the age of 18 and we use reasonable age verification measures to limit access to our Services.

10. Your Privacy Choices

We provide additional disclosures and rights to residents of certain jurisdictions.

11. California Privacy Notice

We provide additional disclosures and rights to California residents.

12. Nevada Privacy Notice

We provide additional disclosures and rights to Nevada residents.

13. Colorado, Connecticut, Utah, and Virginia Privacy Notice

We provide additional disclosures to Colorado, Connecticut, Utah, and Virginia residents.

14. Changes to This Policy

Changes to this Privacy Policy will become effective on the date they are posted.

15. Contact Us

You may contact us for comments or questions in various ways.

1. Personal Data We May Collect, Use, or Disclose

This section identifies the categories and types of personal data that we may collect about you, as well as the purposes for which each category is collected and the types of third parties that may receive the personal data.

For the purposes of this Privacy Policy, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. Personal data includes “personal information” as that term is defined in applicable privacy laws. Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified; or aggregate consumer information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer; and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.

Category of Personal Information

Processing Purposes

Categories of Third Party Recipients (excluding our service providers and processors)

Identifiers, including

Name

Address

Email address

Phone number

Date of birth

Account username

Certain social media account information including user ID IP address

Unique device identifiers

Mobile app identifiers

Device operating system information

Contact you and provide information

Provide customer service

Perform identity and age verification as required under applicable law

Provide and maintain the Services

Facilitate interactive features

Internal analytics

Market our products and services

Market the products and services of others

Internal business purposes, including general business administration

Audit, compliance, legal, policy, procedure, and regulatory obligations

Customer claims and fraud investigation and prevention

Systems and data security

Protecting the safety of our employees and others

Targeted Advertising

Profiling

Any other purpose consistent with your consent and expressed preferences

Advertising networks and data platforms

Commercial information, including

Information about your interests and preferences

Same purposes as noted for "Identifiers"

Advertising networks and data platforms

Financial information, including

Bank account number

Credit card number

Debit card number

Any other financial information

Provide and maintain the Services

Internal business purposes, including general business administration

N/A

Internet or other electronic network activity information, including

Browser version, the pages of our Site or Services that you visit, the time and date of your visit, the time spent on those pages.

Content and information about your communications through the Site or Services

Information using cookies and tracking technologies

Mobile operating system information

Mobile internet browser type

Diagnostic data

Same purposes as noted for "Identifiers"

Advertising networks and data platforms

Geolocation Data , including

Global Positioning System (“GPS”) data

Locational information based upon your IP address

Cell network data

Locational data collected from various devices including your mobile device(s) or vehicles(s)

Internal business purposes, including general business administration

Customer claims and fraud investigation and prevention

Systems and data security

Protect the safety of our employees and others

Internal analytics

N/A

Professional or employment-related information

Employer name

Professional licenses or registrations

Employer industry

Employer size and revenue range

Employment contact information

Employment title

Facilitate interactive features

Internal analytics

Market our products and services

Market the products and services of others

For internal business purposes, including general business administration

Advertising networks and data platforms

Audio, electronic, visual, or similar information, including:

Any original text, audio recordings, photos, videos, and other media you may share on the Services.

Same purposes as noted for “Identifiers”

Advertising networks and data platforms

Inferences about you using any of the above

Any of the above purposes

Advertising networks and data platforms

We may create aggregated, de-identified, or anonymous information from data by removing certain data components (such as your name, email address, or linkable tracking ID) that makes the data identifiable, or through aggregation, obfuscation or other means. Subject to applicable law, our use and disclosure of such aggregated, de- identified, or anonymized information is not personal data or subject to this Privacy Policy.

2. Sources of Personal Data

We may collect personal data about you from the following categories of sources:

Directly from you, through your interactions with us, such as when you use the Site or Services, create an account with us, complete electronic forms, or otherwise contact us via chat, email, or phone.

Through cookies and tracking technologies, as discussed in more detail in Cookies and Tracking Technologies (Section 5 of this Privacy Policy)

From other users of our Sites and Services.

From affiliates within the Company.

From service providers, including those providing payment processing, analytics, advertising, hosting, marketing, customer and technical support (such as when you use our Site’s chatbot), and other services.

From third parties, including our third party data providers, business and marketing partners, analytics providers, ad network providers, ad agencies, and advertisers, including sources of publicly available and other information that we license data from.

From social media and other content platforms, such as Instagram, Meta, X, or LinkedIn, if you access the Services through a third-party connection or log-in or interact with us on these platforms.

We may combine personal data received from one or more of the above sources to improve the quality of our data, which may include data provided to affiliates within the Company.

3. Disclosure of Personal Data

We may disclose personal data that we collect, or you provide, to the following:

Our affiliates. We may share personal information among affiliates within the Company to provide our Services, and for internal administrative purposes.

Our service providers. We share personal information with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use the information for any other purpose. For example, when you use our Site’s chatbot, the information you provide may be recorded and stored by our provider Intercom, in order for us to provide customer and technical support.

Third party platform advertisers. We may share your information with third-party platform providers who assist us in serving advertising to others who may be interested. We also partner with third parties who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location, and/or interests.

Third parties related to compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities.

Third parties related to a change of ownership. If we or our subsidiaries are involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity.

As noted above, the data we disclose to the above parties may include combined personal data received from one or more of the above sources to improve the quality of our data, which may include data provided to affiliates within the Company.

4. Links to Other Sites

The Site may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you for their own commercial purposes. In addition, when you are on the Site you may be directed to other sites and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you "click" on a link, the "click" may take you off the Site onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third-party parties. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Site and to review the third- party privacy policies of all third-party locations and exercise caution in connection with them.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies and analytics services to track activity on and gauge the effectiveness of the Site. Cookies are files with a small amount of data which may include unique identifiers. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Site. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service

Examples of cookies we use:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Site functionality.

Performance-Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.

Functionality-Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you visit our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site.

Advertising-Related. We may use Tracking Technologies to deliver content relevant to your interests on our Site and third-party sites based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.

Analytics Information.
‍We may use Google Analytics or other service providers for analytics services. These analytics services may use cookies and other tracking technologies to help us analyze how users use the Service. Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. Additionally, we may use third-party Service Providers to monitor and analyze the use of our Service. Amplitude is an analytics service provided by Amplitude Analytics, Inc. Firebase is an analytics service provided by Google Inc. You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google.

‍Third-Party Ad Networks.
‍Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/ and its opt-out program for mobile apps at http://www.aboutads.info/appchoices.

In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members' ad networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you. This will affect this and other services, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). If your browsers are configured to reject cookies when you visit this opt- out page, or you subsequently erase your cookies, use a different device or web browser(s), or use a non-browser- based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based Ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Some web browsers and devices used to access our Site may allow you to enable a “Do Not Track” setting, designed to inform websites that you do not want to be tracked. Like many websites, our Site does not support “Do Not Track” functionality.

6. How We Protect Your Information

We care about the security of your personal data, and use commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

7. Data Retention

We will retain your personal data only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal information for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.

8.International Transfers of Your Personal Data

Our Site is operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.

9. Children’s Privacy

The Site is a general audience website and we do not knowingly collect any personal information from children younger than the age of eighteen (18) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than 18. If you become aware that a child has provided us with personal data, please contact us via email at DPO@textedly.com. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

10. Your Privacy Choices

We make every effort to promptly process all unsubscribe requests.

a. Opting of promotional electronic communications from us
We may use your personal information to send you updates regarding existing products and services, information about new products and services, upcoming events, surveys, and other announcements and inquiries. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or communicate your opt-out request using the information below. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with the Service or for other reasons disclosed in this Policy (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at DPO@textedly.com.

b. Information on Opt-out of Campaigns for our Clients' Users
We offer services enabling its Clients to send messages via text messages. This Section is designed for those users who received a message from a Client. If you believe you have received unwanted, unsolicited text messages from our platform, please contact us via email at DPO@textedly.com. To unsubscribe from any Client campaign, simply text 'STOP', 'REMOVE', 'CANCEL', 'END', 'QUIT', 'OPTOUT' or 'UNSUBSCRIBE' to the originating short code or contact us via email at DPO@textedly.com. We will send you a SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us unless you opt-in to a different campaign. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. As always, message and data rates may apply for any messages sent to you from us and to us from you.

c. Updating your information
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. You may to provide updates and changes to your Personal Information by contacting us via email at DPO@textedly.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails or in some cases by logging into your Site account and changing your communication preferences. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and Site announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact please contact us via email at DPO@textedly.com.

d. U.S. privacy rights
Certain U.S. jurisdictions provide residents with certain rights with respect to their personal information or personal data as defined under applicable law. These rights are subject to the specific laws of that jurisdiction and that certain other rights might apply. Please review our California Privacy Notice; Nevada Privacy Notice; and Colorado, Connecticut, Utah, and Virginia Privacy Notice for more information on rights and terms specific to your location or place of residence.

11. California Privacy Notice

This California Privacy Notice supplements the information contained in the rest of our Privacy Policy and is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy. For the purposes of this California Privacy Notice, except where a different definition is noted, “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 California resident or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulation.

If you are a visually-impaired customer, a customer who has another disability or a customer who seeks support in another language, you may access this California Privacy Notice by emailing us at DPO@textedly.com.

a. Personal Information We Collect
‍We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Identifiers

Protected classification characteristics under California or federal law

Professional or Employment information

Internet or other electronic network activity information

Geolocation data

Audio, electronic, visual, or similar information

Commercial information

Inferences

b. Use of Personal Information
‍We may use or disclose the personal information we collect for one or more of the following purposes:

Contact you and provide information

Provide customer service

Perform identity and age verification as required under applicable law

Provide and maintain the Services

Facilitate interactive features

Internal analytics

Market our products and services

Market the products and services of others

Internal business purposes, including general business administration

Audit, compliance, legal, policy, procedure, and regulatory obligations

Customer claims and fraud investigation and prevention

Systems and data security

Protecting the safety of our employees and others

Any other purpose consistent with your consent and expressed preferences

Cross-context behavioral advertising

Profiling

c. Disclosure of Personal Information
We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal information was collected.

We may “share” personal information with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms.

In the last 12 months (from the last updated date listed at the top of this Privacy Policy), we have “shared” the following categories of personal information:

Identifiers

Professional or employment information

Internet or other electronic network activity information

Commercial information

Inferences

d. Retention of Personal Information
‍We will retain your personal data only for as long as is necessary to provide you with Services, to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain certain personal information for internal analysis purposes. This information is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position, including regard to applicable statutes of limitations, litigation or regulatory investigations.

e. Your California Privacy Rights
‍The CCPA provides consumers (California residents) with specific rights regarding their personal information. If you are a California resident, you may have the following rights under applicable California law:

Right to know and access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.

Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.

Right to correct inaccurate personal information. You have the right to request the correction of inaccurate personal information.

Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your personal information by a business.

Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.

Sharing with third parties for their own direct marketing purposes. We do not disclose this personal information to third parties for their own purposes without your consent. If you wish to request information regarding such practices under California’s “Shine the Light” Law, please Contact Us. You must include your full name, email address, and postal address in your email or mail request so that we can verify your California residence and respond.

How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices.
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f. Notice of Right to Opt-Out of Sale/Sharing
‍California residents may opt out of the “sale” or “sharing” of their personal information. As noted above, we may “sell” and/or “share” your personal information with Enterprise Customers, advertising networks, and data platforms. You may opt-out by following the instructions in Your Privacy Choices.‍

We do not knowingly sell or share the personal information of minors under 16 years of age without legally-required affirmative authorization. If you are a parent or guardian and you believe that your child has provided us with information without your consent, please review the Children’s Privacy section and contact us by email at DPO@textedly.com.

You can also opt out of such sales or sharing by clicking the Your Privacy Choices link at the bottom of our website and selecting your preferences. You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. Please note that if you do not have an account with us or if you are not logged into your account, your opt out request will be linked to your browser identifier only and not linked to any account information, because the connection between your browser and your account is not known to us.
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g. Notice of Financial Incentive
‍We may offer promotions and discounts on products or services, for example, through our 14-day free trial. The availability of these promotions to you at any given time will vary. If and when we offer such programs, we may ask for your personal information including: your employer, email address, account login information, first and last name, and phone number, as a prerequisite to your participation.

You may opt-in to the above promotions by visiting the Site. You may withdraw from these promotions at any time by contacting us at DPO@textedly.com. If you withdraw from these programs, we will not contact you for at least twelve (12) months before requesting your participation again.

The value we place on personal information collected for these promotions varies, but we estimate it equals the additional spending per promotion participant, compared to individuals for whom we do not have email addresses, shopping history and preferences, or other collected information.

12. Nevada Privacy Notice

We do not “sell” personal information as defined by Nevada law. However, Nevada residents have the right to request to opt out of any future sale of their personal information under Nevada SB 220. If you are a Nevada resident and would like to make such a request, please follow the instructions in Your Privacy Choices. You must include your full name, email address, and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal data after the receipt of your request, we will make reasonable efforts to comply with such request.

13. Colorado, Connecticut, Utah, and Virginia Privacy Notice

This Privacy Notice applies to any Colorado, Connecticut, Utah, and Virginia residents about whom we collect personal information (“consumers”). The provisions contained within this section, in addition to the disclosures throughout the rest of this Policy, are intended to provide notices in compliance with the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”). This section does not apply to certain personal data that is collected from an individual in a business-to-business or employment context, or data that is already subject to certain federal and state regulations, such as protected health information.

For the purposes of this section, “personal data” means information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include de-identified data or publicly available information.

a. Our Personal Data Practices

‍The CPA, CTDPA, UCPA, and VCDPA provide rights to residents of Colorado, Connecticut, Utah, and Virginia, respectively, to receive certain disclosures and access regarding collection, use, sale, and sharing of personal data. Detail about what kinds of personal data we may collect or have collected, how we collect it, why we collect it, and who we may disclose it to is found in the Personal Data We May Collect, Use, and Disclose;Sources of Personal Data; and Disclosure of Personal Data sections of this Privacy Policy.

We may “sell” and/or “share” personal data with third party advertising networks and platforms for purposes of providing targeted behavioral advertising on those platforms.

b. Your Privacy Rights
‍If you are a resident of Colorado, Connecticut, Utah, or Virginia, you have the following rights under applicable law in relation to your personal data, subject to certain exceptions:

Right to know and access. You have the right to know what personal data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.

Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal data that we collect about you.

Right to correct inaccurate personal data. You have the right to request the correction of inaccurate personal data.

Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

Right to opt out. You have the right to opt-out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.

Rights concerning sensitive personal data. If you are a Connecticut, Colorado, or Virginia resident, we cannot process your sensitive data or your sensitive data inferences, or use your personal data for certain purposes without your affirmative consent. If you are a Utah resident, you have the right to opt out of having your sensitive personal data processes.

How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Your Privacy Choices.

How to appeal decisions about your rights. Connecticut and Virginia residents can appeal our decisions concerning privacy rights requests, as follows:

Colorado residents. If you are a Colorado resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Colorado’s Office of the Attorney General by phone at (720) 508-6000 or by submitting a form here.

Connecticut residents. If you are a Connecticut resident and want to appeal our decision with regard to a request that you have made, please Contact Us. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Connecticut’s Office of the Attorney General by phone at (860) 808-5420 or by submitting a form here.

Virginia residents. If you are a Virginia resident and want to appeal our decision with regard to a request that you have previously made, please Contact Us or notify the Office of the Attorney General of Virginia online here. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may contact Virginia’s Office of the Attorney General by phone at (804) 786-2071, written correspondence to 202 North 9th Street, Richmond, Virginia 23219, or online here.

14. Changes to this Privacy Policy

This Privacy Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. Appropriate public notice will be given concerning material amendments or changes to this Policy. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above.

We will not use your previously collected Personal Information in a manner materially different than indicated at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

15. Contact Us

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site or our Services, please contact us at DPO@textedly.com. Alternatively, you may submit this form to contact us regarding privacy related inquires.