Promotion privacy policy

Introduction

Obviously Social, LLC (“Company” or “We”) respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit our website offsamples.com (our “Website”) and participate in our giveaways, sweepstakes, contests, and other promotions (each, a “Promotion”) as well as our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website; and

• In connection with the Promotion.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Obviously or any third party (including our affiliates, subsidiaries, and Promotion partners); or

• Any third party (including our affiliates, subsidiaries, and Promotion partners or sponsors), including through any application or content (including advertising) that may linked to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website or participating in the Promotion, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website or participation in the Promotion after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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Children Under the Age of 18

Our Website and this Promotion is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website, or in connection with the Promotion. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or register on the Website, use any of the interactive features of this Website, including entering into the Promotion, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

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Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Website and participants in the Promotion, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, Instagram Handle, or other social media account information (“personal information”);

• That is about you but individually does not identify you; and/or

• About your internet connection, the equipment you use to access our Website, and usage details.

We may collect this information:

• Directly from you when you provide it to us.

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

• From third parties, for example, our Promotion partner and other business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or for the Promotion and when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of any promotional consideration. You may be required to provide additional information before receiving your promotional consideration, to the extent required by law.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, such as:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It may help us to improve our Website and our promotional offerings, including with respect to the Promotion, and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Obviously, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We may also tie this information to personal information about you that we collect from other sources or you provide to us. We currently do not respond to “do-not-track” browser settings and other similar mechanisms.

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Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

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We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

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How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you and to administer the Promotion.

• To provide you with information, products, or services that you request from us.

• To fulfill any other purpose for which you provide it.

• To provide you with notices and other information about the Promotion.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including fulfilling our legal obligations with respect to the Promotion.

• To notify you about changes to our Website or the Promotion.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. We may also use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria, even if we do not share your personal information with them.

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Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To contractors, service providers, and other third parties we use to support our business.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website and Promotion users is among the assets transferred.

• To third parties to market their products or services to you if you have consented to these disclosures.

• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us when you provide the information.

• With your consent.

Our promotion partner OFF! will not be receiving any of your consumer data.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our Promotion terms and conditions and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Obviously, our partners, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction.

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Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to samples@obvious.ly.

• Promotional Offers from Obviously. If you do not wish to have your personal information used by Obviously to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to samples@obvious.ly. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. 
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you must opt-out with them directly. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. For example, you can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

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Accessing and Correcting Your Information

You may send us an email at samples@obvious.ly to request access to, correct or delete any personal information that you have provided to us. 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.

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Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to samples@obvious.ly.

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Obviously is not a business which is subject to or regulated by the California Consumer Privacy Act of 2018 (“CCPA”). However, Obviously voluntarily complies with the general principles of the CCPA with respect to all individuals, wherever located, as detailed below:

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• Obviously grants individuals the right to know what personal information it collects or discloses about them, including the categories of third-parties who may have received their data. Obviously does not sell personal information and collects information for the purpose of connecting influencers with brands, or under circumstances, administering brand interactions with consumers.
• Obviously discloses the purpose for which information is collected at the time of collection.  
• Upon request by an individual, Obviously will update, disclose or delete the personal information it maintains, and will comply with requested restrictions on disclosure of that personal information to third-parties.
• Obviously does not and will not discriminate against any individuals, including those who exercise any of the foregoing rights.

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In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A 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.

YES

B. 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.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics 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).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. 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.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. 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.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

[YES/NO]

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

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[Category A: Identifiers.]

[Category B: California Customer Records personal information categories.]

[Category D: Commercial information.]

[Category F: Internet or other similar network activity.]

[Category K: Inferences drawn from other personal information.]

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We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Internet cookie data recipients, like Google Analytics and social media companies.

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Sales of Personal Information

In the preceding twelve (12) months, Company has sold the following categories of personal information:

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[Category A: Identifiers.]

[Category B: California Customer Records personal information categories.]

[Category D: Commercial information.]

 [Category F: Internet or other similar network activity.]

 [Category K: Inferences drawn from other personal information.]

• Advertisers and marketing agencies.

• Affiliates.
• Partners. 
• Clients.
• Internet cookie data recipients, like Google Analytics and social media companies.

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If you have any questions or concerns regarding your privacy rights, please send an email to samples@obvious.ly.

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Your EU Privacy Rights

Obviously voluntarily complies with the EU General Data Protection Regulation ((EU) 2016/679) (GDPR). Specifically, Obviously provides individuals in the EU their rights under the GDPR including the right to:

• Information about your personal data maintained by us;
• Access your personal data maintained by us.
• Correct your personal data maintained by us.
• Erase your personal data maintained by us, also known as the right to be forgotten.
• Restrict processing of your personal data maintained by us.
• Object to processing of your personal data by us.
• Receive a copy of your personal data or transfer your personal data to another data controller.
• Not be subject to automated decision-making.
• Be notified of a data security breach.

For more information about our GDPR specific privacy practices, please visit studio.obvious.ly/privacy.

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Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

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Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

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Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Obviously Social, LLC
3 World Trade Center
175 Greenwich Street, 28th Floor
New York, NY 10007
samples@obvious.ly

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