Last Revised: 2/8/23
1. Personal Information We Collect
We collect personal information from you so that we can provide you with the services to which you subscribe. We will only collect the minimum amount of information necessary for us to fulfill our obligation to you.
1.1. Data provided directly by you
- Contact information. When you complete our “Contact” page or subscribe to our email list, you will be asked to provide your first name, last name, and email address, and have the option to provide your phone number and other details. We will use this transaction information to respond to your request, personalize your experience, perform analytics/identify usage trends, and inform our advertising and marketing.
1.2 Personal information generated and/or automatically collected during your use of the website.
- IP address. We may use your IP address to help diagnose problems with our server and to administer the website by identifying which areas of the website are most often used, and to display content according to your preferences. Your IP address is the number assigned to computers connected to the internet. This cannot personally identify you and is helpful to use for the purposes of marketing and improving our website. This type of data collection does not follow a user’s activities on any other websites in any way and may also be shared with business partners and advertisers on an aggregate basis.
- Analytics information. We may collect analytics data or use third-party analytics tools, such as Google Analytics, to help us measure traffic and usage trends and the demographics of our users in order to improve our website and services. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners.
Please note that the information that you are providing to us (“Personal Data”) is voluntary and by providing this information to Curtis you are giving us consent for use to use, collect, and process this Personal Data. You may opt out or request for Curtis to delete your Personal Data at any point by emailing email@example.com.
2. How We Use Your Personal Data
In addition to the uses described above, we may collect and use Personal Data to:
2.1 Provide, maintain, improve, and develop the website and services.
2.2 Communicate with you to provide support and other important messages.
2.3 Comply with legal and regulatory requirements and proceedings.
3. Our Sharing and Disclosure of Personal Information
Curtis will not share your personal information with third parties, with the exception of third parties mentioned in Section 5.
4. Control Over Your Personal Information
You can stop receiving promotional email communications by clicking on the “unsubscribe link” provided in such communications. You may not opt out of service-related communications (e.g., transactional communications, changes/updates to features of the services, technical and security notices). Please see our Terms of Service for more information on communications from or on behalf of Curtis.
5. How We Store and Protect Your Information
- We retain your Personal Data for the minimum amount of time necessary to provide you with the subscription and accompanying services that you requested from us. We may retain certain Personal Data for longer periods of time if necessary for legal, contractual, and accounting purposes.
- Keeping your information safe. We care about the security of your information and Personal Data that you provide to us is stored internally or through a data management system. Your Personal Data will only be accessed by those who help to obtain, manage, or store that information, or who have a legitimate need to know such Personal Data, such as our internet service provider and payment processers. However, no security system is impenetrable and we cannot guarantee the security of our systems. Please recognize that protecting your personal information is also your responsibility. Accordingly, we strongly recommend that you change your passwords often, use a combination of letters and numbers, make sure you use a secure browser, and otherwise take precautions when communicating your personal information on the internet. If you know or have reason to believe that any of your Personal Data has been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Personal Data, please contact us following the instructions in the Contact Us section below.
6. Third-Party Websites
We provide links to third party sites. Since we do not control these websites, we encourage you to review the privacy statements posted on these (and all) third party sites. Curtis is not responsible for the privacy statements or practices of sites and services controlled by other companies or organizations.
7. Children’s Online Privacy Protection Act
We comply with the Children’s Online Privacy Protection Act (COPPA). Therefore, the website is not intended for use by anyone under the age of 13 years, and we do not knowingly collect information from anyone under 13 years of age without the consent of a parent or guardian.
8. Region Specific Disclosures
Depending on where you reside, you may also have additional legal rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases. The laws of California, Virginia, Colorado and Connecticut grant some or all of the following rights to consumers who reside in those states:
- The right to request information about personal information that we have collected about you in the 12 months preceding your request (including the categories of information collected, the source of that information, the business purpose of that collection, the categories of third parties with whom that information is shared, and the specific pieces of personal information collected about that particular customer);
- The right to receive requested information in a readily-usable format if provided electronically;
- The right to request that we delete any personal information about you that we have collected (although we may be entitled to retain some information for certain purposes);
- The right to opt-out of “sales” of personal information to third parties, the sharing of personal information with third parties for targeted advertising purposes, and/or the processing of personal information for targeted advertising purposes;
- The right to update or correct any personal information which is out of date or incorrect; and
- The right to be free from discrimination based on your exercise of your privacy rights.
To exercise your rights with respect to our website, please contact us at firstname.lastname@example.org.
- California. If you are a resident of the State of California in the United States, please visit https://oag.ca.gov/privacy/ccpa for additional California-specific privacy disclosures pursuant to the California Consumer Privacy Act (CCPA).
- Shine the Light Law. Curtis does not disclose personal information to third parties for those third parties’ own direct marketing purposes.
- Right to Know and Delete. Consumers who are California residents have the right to know certain information about our data practices in the preceding 12 months. In particular, they have the right to request the following from us:
- The categories of personal information we have collected about them;
- The categories of sources from which the personal information was collected;
- The categories of personal information about them that we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and
- The business or commercial purpose for collecting or selling the personal information.
In addition, in certain circumstances, California consumers have the right to delete the personal information we have collected from them.
To exercise any of these rights, California consumers should submit a request to: email@example.com with the Subject labeled “California Privacy Rights Request”. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
- Authorized Agent. You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
- Do Not Sell My Personal Information. Curtis does not sell personal information as the term “sell” is defined under the CCPA.
- Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
If you are a California resident under the age of 18, you may request and obtain removal of content or information you have publicly posted on such site. To make such a request, please send an email with the subject line “California Minor Content Removal Request” to firstname.lastname@example.org. Please specify in your request the website to which your request relates to and the specific information or content that you would like removed.
We may deny deletion requests in whole or in part as permitted or required by applicable law. We do not charge a different price or rate or provide a different level or quality of goods or services based on your exercising your CCPA rights. We do not sell personal information in the ordinary sense of that term, that is, we do not provide your personally identifiable information to third parties in exchange for money. As under California law, sharing information with third parties for targeted advertising purposes may be considered a “sale” of personal information. California residents have the right to opt out of such sharing.
- Nevada. If you are a resident of the State of Nevada, you have the the right to request that a company not sell your personal information for monetary consideration to certain other parties. This right applies even if your personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, please send an email with the subject line “Nevada Resident Do Not Sell Request” to email@example.com.
9. Under the General Data Protection Regulation (EU) 2016/679 (known as GDPR), Curtis functions as a “data controller” when we process certain Personal Data from users who access Curtis through a subscription in order to maintain and provide our services, and for any marketing communications that users may opt in to receive.
If you are a user accessing our services from within the European Economic Area (such user herein referred to as a “Data Subject”), we may ask for your consent so that we may process your Personal Data. For example, we will ask for your consent to send your marketing information. However, in certain situations, applicable data protection law allows us to process your Personal Data without needing to obtain your consent. For example:
- To perform out contractual obligations to you, including fulfilling requests you have made, contacting you in relation to any issues with your use of the services, or where we need to provide your Personal Data to our service providers who help us operate the services.
- To comply with laws, regulators, court orders or other legal obligations.
We also use automated data collection tools to corelate your IP address with your location, sufficient to recognize your zip or postal code in order to display local sponsor or underwriter information or notify you of local events.
We may use your Personal Data as described above and for other purposes, including the following:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that Personal Data to respond to your inquiry.
- To provide, supports, personalize, and develop our services, including without limitation, receiving, processing, and responding to feedback.
- To provide to our third-party service providers to allow them to provide features on our behalf as described below.
- To create, maintain, customize, and secure your account with us.
- To personalize your experience with the services and to deliver content and service offerings relevant to your interests and/or geographic location, including targeted offers and ads through our services, third-party sites, and via email (with your consent), in accordance with applicable law.
- For testing, research, analysis, and service development, including to develop and improve our services through focus groups and surveys.
- To communicate information to you (such as, new features, products or services), and to send you relevant emails and communications that may be of interest to you and that you have opted in to receive
- To help maintain the safety, security, and integrity of our services, databases, and other technology assets, and business, including without limitation, to investigate suspected violations of our Terms of Service, suspected fraud or other unlawful activity.
- To enforce our agreements, terms, conditions, and policies, and to notify you of any updates to the same.
- As may be required by law or by a court order, in which case we shall attempt to notify you and work with you to seek to limit the scope of the required disclosure.
- With your consent and as permissible under applicable laws and regulations.
EUROPEAN RESIDENTS: YOUR DATA RIGHTS
When we are operating as a controller, Data Subjects are provided with certain rights related to your Personal Data. Note that in circumstances where we are operating as a processor, you may have similar rights with the controller. In those circumstances, please contact your controller to exercise your rights. We will work with them and with you to address any requests you may have related to exercising our rights as described below.
Please note that the rules in your country may provide you with additional rights or may limit the rights noted below. In all cases, we will act in accordance with applicable laws.
- Right of access. You may obtain confirmation about whether Personal Data concerning you is processed, and request access to Personal Data, including the purposes of the processing, the categories of Personal Data concerned, a copy of the Personal data, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed. However, this is not an absolute rights and the interests of other individuals may restrict your right of access.
- Right to rectification. You may have inaccurate Personal Data concerning you corrected. Depending on the purposes of the processing, you may have the right to have incomplete Personal Data completed, including by providing a supplementary statements.
- Right to erasure (“right to be forgotten”). Under certain circumstances, you may have Personal Data concerning you erased.
- Right to restriction of processing. Under certain circumstances, you may restrict us from processing your Personal Data. In this case, the respective data may only be processed by us for certain purposes.
- Right to data portability. Under certain circumstances, you may receive the Personal Data concerning you in a structured, commonly-used, machine-readable format, and you may have the right to transmit that data to another entity without hindrance from us.
- Right to object. Under certain circumstances, you may object, on grounds relating to your particular situation, or at any time where Personal Data is processed for direct marketing purposes to the processing of your Personal Data by us, and we can be required to no longer process your Personal Data. If personal Data concerning you is processed for direct marketing purposes, you also have the right to object at any time to the processing of that Personal Data for that marketing, including profiling to the extent that it is related to the direct marketing. In this case, we will no longer process your Personal Data for such purposes.
If you have provided your consent for our processing of your Personal Data, you may revoke that consent at any time by sending your request to firstname.lastname@example.org. That withdrawal will not impact the lawfulness of the processing prior to your revocation of consent.
INTERNATIONAL DATA TRANSFERS
However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure of your Personal Data pursuant to the requirements of the GDPR.
11. Contact Us
Please note that email communications will not necessarily be secure; accordingly, please do not include credit card information and/or other sensitive personal information in your email correspondence with us.