SECTION 1 - SCOPE
SECTION 2 - PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
(a) Information You Provide to Us Directly. We may collect the following personal information that you provide to us.
• Account Creation: We may collect information when you create an account or place an order with us, such as name, email address, mailing address, and phone number.
• Style Quiz: When you complete the style quiz, we may collect information such as your email address, and information about your child including your child’s date of birth, gender, and name in order to customize our Services.
• Your Communications with Us: We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, apply for a job, or otherwise communicate with us.
• Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Interactive Features: We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., commenting functionalities, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
• Sweepstakes or Contests: We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
• Business Development and Strategic Partnerships: We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications: We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
(b) Information Collected Automatically. We may collect personal information automatically when you use our Services
• Automatic Data Collection: We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
• Location Information: We may collect precise location information, such as [Insert example] when you visit our website, or otherwise use our Services.
• Cookies: Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
• Operationally Necessary: This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance-Related: We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related: We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
(c) Information Collected from Other Sources We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. We may also collect your name and email address from other users if they send you a gift through our Services.
SECTION 3 - HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
(a) Provide Our Services. We use your information to fulfil our contract with you and provide you with our Services, such as:
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.
(b) Administrative Purposes. We use your information for various administrative purposes, such as:
• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention and debt collection;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading or enhancing our Services;
• Developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions and other compliance activities;
• Enforcing our agreements and policies; and
• Complying with our legal obligations.
(c) Marketing and Advertising our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
(d) Other Purposes. We also use your information for other purposes as requested by you or as permitted by applicable law.
• Consent: We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• De-identified and Aggregated Information: We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.
• Share Content with Friends: Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).
SECTION 4 - HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
(a) Disclosures to Provide our Services. The categories of third parties with whom we may share your information are described below.
• Service Providers: We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, debt collection services, customer service, and related services.
• Business Partners: We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
• Affiliates: We may share your personal information with our company affiliates.
• Other Users/Website Visitors: As described above in “Personal Information We Collect,” our Services allow you to share your User Content with other Users/publicly, including to those who do not use our Services.
• APIs/SDKs: We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
(b) Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
(c) Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
SECTION 5 - YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
• Text Messages: You may opt out of receiving text messages from us or our debt collection service providers by following the instructions in the text message you have received or by otherwise contacting us.
• Mobile Devices: We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• “Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising: You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
• The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Request Restriction of or Object to our processing of your personal information; and
• Withdraw your Consent to our processing of your personal information.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us”below. We will process such requests in accordance with applicable laws.
SECTION 6 - SECURITY OF YOUR INFORMATION
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
SECTION 7 - INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
SECTION 8 - RETENTION OF PERSONAL INFORMATION
SECTION 9 - SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Dopple has collected about them and whether Dopple disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below regarding the categories of personal information that may be collected by Dopple, and the categories of third-party information it is disclosed to for a business purpose:
• Identifiers, such as a real name, postal address, online identifier, Internet Protocol address, email address, or other similar identifiers. This category may be disclosed to advertising partners, service providers, or other users/public (name, online identifier)
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name, physical characteristics or description, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information. This category may be disclosed to advertising partners, service providers, or other users/public (name)
• Protected classification characteristics under California or federal law, such as sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions). This category may be disclosed to service providers.
• Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category may be disclosed to advertising partners and service providers.
• Internet or other electronic network activity, such as browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement. This category may be disclosed to advertising partners and service providers.
• Geolocation data, such as physical location or movements. This category may be disclosed to advertising partners and service providers.
• Professional or employment-related information (job applicants only), such as current or past job history or performance evaluations. This category may be disclosed to service providers.
• Inferences drawn from other personal information to create a profile about a consumer, such as a profile reflecting a consumer's preferences, characteristics, predispositions, behavior, and attitudes. This category may be disclosed to advertising partners and service providers.
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA
California residents have the right to opt out of the “sale” of their personal information. Under the CCPA, “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money).
Dopple may “sell” personal information to advertising partners. The categories of personal information we may have “sold” in the preceding twelve months are listed below:
• Identifiers, such as a real name, postal address, Internet Protocol address, email address, or other similar identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name.
• Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity, such as browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
• Geolocation data, such as physical location or movements.
• Inferences drawn from other personal information to create a profile about a consumer, such as a profile reflecting a consumer's preferences, characteristics, predispositions, behavior, and attitudes.
Dopple’s business and commercial purposes for “selling” personal information can be found in “How We Use Your Personal Information” above. Dopple does not have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Opt-out of “Sales.” California residents may opt-out of the “sale” of their personal information by contacting us as set forth in “Contact Us” below.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Referral Programs. As described above in “How We Use Your Personal Information” (“Share Content with Friends”), we may offer referral programs. We may offer incentives to you such as discounts or promotional credit in connection with these programs, wherein you provide personal information regarding your friends (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These referral programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of the referred party’s data to us depends on whether the referred party ultimately becomes a Member and uses our Services. Said value will be reflected in the incentive offered for each referral.
California Shine the Light. The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.
SECTION 10 - SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at firstname.lastname@example.org with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
SECTION 11 - CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, or you wish to review information you have provided to us about your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.
SECTION 12 - OTHER PROVISIONS
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
SECTION 13 - CONTACT US
470 University Avenue
Los Altos, CA 94022