(Effective January 16, 2020)
WHAT INFORMATION WE COLLECT AND WHY WE COLLECT IT
We collect two basic types of information – Personal Information and Anonymous Information – and we may use these two types of information to create a third type of information, Aggregate Information.
- Personal Information – “Personal Information” is information that is collected online, and either directly or indirectly identifies individuals. When you engage in certain activities on the website or app, we may ask you to provide certain Personal Information. Anonymous Information (defined below) that is associated with Personal Information is also considered Personal Information. We may collect the following Personal Information from you:
- Registration information you provide us when you create an account, including your name, date of birth, gender, username, password, e-mail address, and telephone number;
- Transaction information you provide us when you purchase a product or service from our website or app, including your payment information, telephone number, and shipping address;
- Information you provide in public forums on the website or app (if any);
- Information you send on or through the website or app, whether directly to another user or within a group, using our message, chat, post, or similar functionality, where we are permitted by law to collect this information;
- Profile information you choose to share, such as your city, state, favorite bands, favorite shows, favorite music videos, favorite quote, your personal website, a picture, and a general description of yourself; and
- Other Personal Information you choose to share, such as information you provide to us when you link your account on the website or app to third-party social networking sites or platforms.
- Anonymous Information – “Anonymous Information” is information that does not and cannot reasonably be used to directly or indirectly identify an individual user. We use and share this Anonymous Information with third parties to improve the content and functionality of the website or app and our affiliated websites or apps, to better understand our customers and markets, and to improve our products and services. Anonymous Information may include:
- Information collected automatically through the operation of the website or app, such as cookies, flash cookies, or web beacons, which are not linked to any Personal Information. These technologies provide tracking data that allows us to implement useful features and deliver relevant content to you based on your preferences, location, or usage patterns. We may associate some of this tracking data with your registration account if you choose to create one, in which case, we will treat it as Personal Information; and
- Location information when you visit or use the website or app, including location information provided by a mobile device interacting with the website or app (through beacon technologies or otherwise).
- Aggregate Information – “Aggregate Information” is information created through use of Personal Information and Anonymous Information about the categories of users, which does not and cannot reasonably be used to identify an individual user, such as:
- Usage, viewing, and technical data, including your device identifier or IP address, collected automatically when you use our website or app, or open e-mails that we send.
HOW WE COLLECT YOUR INFORMATION
We collect information from you to improve our services and to provide you with an optimal experience. Accordingly, we collect your information in the following ways:
- Directly – When you provide information to us by: (i) requesting products, services, or information, (ii) registering an account, (iii) participating in public forums or other activities on the website or app, (iv) linking your account on the website or app with your account(s) on social networking sites, or (v) otherwise interacting with us;
- Passively – Through technology, such as cookies, web beacons, other technologies, or our mobile app through our vendors;
- From third parties – When other trusted sources provide us with information to update or supplement the information you provided to us or information we collected automatically, as permitted by law.
HOW WE USE YOUR INFORMATION
We collect, store, and use your Personal Information for the specific reasons that you provided such information and to provide you with a safe and customized experience on the website or app. We may use information collected from you in any of the following ways:
- To create your user account;
- To provide you with products and services at your request;
- To identify and suggest products or services;
- To prevent fraud or potentially illegal activities;
- To provide technical support and respond to user requests;
- To optimize or improve the website, app, products, services, or operations;
- To facilitate communications with you (e.g., informing you of new products or promotional offers, verify your account, informational and operational purposes, customer service, etc.).
We may use Anonymous Information and Aggregate Information for research and analysis to improve our products and services and to better understand our customers and markets.
HOW WE SHARE YOUR INFORMATION
We generally do not share your information with third parties, except in limited circumstances. Such circumstances may include: sharing with our parents, affiliates, or subsidiaries; co-branded promotions; or when another company performs services for us. These companies are prohibited from using your information in any other way than what you allow or what is required by law.
- Related Parties – We may share Personal Information that you provide us with our parents, affiliates, and subsidiaries. If you do not want us to share your Personal Information with our related companies for their marketing or other purposes, you may opt-out by contacting us at email@example.com.
- Social networking sites – If you link your account on the website or app to other social networking sites (e.g., Facebook, Instagram, Snapchat, Twitter), we may exchange or otherwise provide information about you with these social networking sites, with your consent.
- Our business partners – Unless they are acting on our behalf or you provide your Personal Information as part of a co-branded promotion, we will obtain your consent before we share your contact information with advertisers, business partners, or other entities that are not related to CJ. However, we may share Anonymous and Aggregate Information to develop and deliver targeted advertising to users of the website or app and on the websites of third parties.
- Our service providers – We may share your information with companies that provide services to us, including companies that assist with the operation of our services, payment processing, data processing, user and business analytics, account management, advertising, and other services (e.g., Google Analytics). We may also enter into agreements with third parties that provide the technology which allows us to customize the advertising and marketing notices you receive while using our services. We make reasonable efforts to direct all such third-party service providers to maintain the confidentiality of the information shared with them and to not use your information for any purpose other than to provide services on our behalf.
- Other parties in connection with a transfer of assets – If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, we may sell or transfer your information to one or more third parties as part of that transaction.
- Other parties with your consent – We may share or disclose your information with your consent, such as when you authorize a third-party website or other parties and applications to connect with our website or app.
HOW WE PROTECT YOUR INFORMATION
We take precautions—including administrative, technical, and physical measures—to safeguard your Personal Information against loss theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. While we make efforts to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining your information. In the unlikely event that a data breach occurs, whether by accident or unlawful interference, we will take necessary precautions to do our best to promptly notify you.
You can help us by also taking precaution to protect your Personal Information when you are on the Internet. Change your passwords often using a combination of letters, symbols, and numbers, and make sure you use a secure web browser.
YOUR CHOICES AND CONTROLS
You may use parts of the website, app, and some of our services without providing any Personal Information. If you have previously provided Personal Information to us and have subscribed to any services on the website or app, and you no longer wish to receive such services, please discontinue your subscriptions by clicking on the “unsubscribe” link at the bottom of message and following the instructions to be removed from our mailing lists. You may also contact us at firstname.lastname@example.org to unsubscribe or make modifications to your account. Please note, however, that we may retain records of your Personal Information as necessary to comply with applicable federal, state, or local laws.
If you would like to review or change the Personal Information that you have provided to us, please contact us at email@example.com. We will take reasonable steps to respond to requests for changes and updates to your Personal Information in our possession.
PRIVACY OF CHILDREN
We support the guidelines and regulatory requirements provided for in the Children’s Online Privacy Protection Act of 1998 (“COPPA”): http://www.ftc.gov/ogc/coppa1.htm. We do not knowingly collect any Personal Information from children under age 13. Children under 13 are expressly prohibited from providing any Personal Information to us through the website and app. In the event that we learn that we have inadvertently collected Personal Information from a child under the age of 13, we will take reasonable measures to promptly remove such information from our records.
At various places on the website or app, we may ask users for their age. By using the website or app, and their respective services, you agree to respond truthfully about your age.
If you have any reason to believe that a child has provided any Personal Information to us, please contact us at firstname.lastname@example.org and we will make reasonable efforts to delete the provided information or otherwise protect the user.
If you are a California resident, the California Consumer Privacy Act of 2019 (CCPA), and certain other privacy and data protection laws, as applicable, permits you to request certain information, no more than twice per year, regarding your personal information. You have the right to request disclosure of personal information we collect about you, including: (1) the categories of personal information we have collected; (2) the categories of sources from which the personal information is collected; (3) our business or commercial purpose for collecting personal information; (4) the categories of third parties with whom we share personal information, if any; and (5) the specific pieces of personal information we have collected from you. Please note that we are not required to (1) retain any personal information about you that was collected for a single one-time transaction if such information is not retained in the ordinary course of business; (2) re-identify or otherwise link any data that is not maintained in a manner that would be considered personal information in the ordinary course of business; and (3) provide your personal information more than twice in a 12-month period.
Subject to certain exceptions as set out herein, you have the right to request deletion of your personal information stored by us. On a verifiable request from you, we will: (1) delete your personal information from our records; and (2) instruct any service providers to delete your personal information from their records. Please note that we are not required to delete any personal information that is necessary: (1) for a transactional need; (2) for risk management such as detecting security incidents and protecting against malicious or illegal activity; (3) to improve functionality; (4) to exercise or protect free speech as provided for by law; (5) for compliance with the California Electronic Communications Privacy Act; (6) to engage in bonafide research; (7) to facilitate a business relationship with you; (8) to comply with an existing legal obligation; and (9) for a lawful internal purpose.
We will not discriminate against you if you exercise your CCPA rights. This means that we will not, among other things, on the basis of a CCPA request: (1) deny goods or services to you; (2) charge you different prices or rates; (3) provide a different level or quality of goods or services to you; (4) or suggest that you will receive a different price, rate, level, or quality of goods and services. Please note that we are allowed to charge a different price or rate, or provide a different quality or level, for goods and services to you if the difference is reasonably related to the value that your personal information provides to us.
To make a California personal information request, please send an email to email@example.com with the subject line “California Privacy Request” or write us at:
RE: CA Privacy Rights
CJ ENM America, Inc. / KCON USA
1600 Rosecrans Ave., Bldg. 2A, Ste. 301
Manhattan Beach, CA 90266
We will do our best to respond to you within thirty (30) days of receiving such a request.
We value your use of our products and services and we are dedicated to protecting your personal information with care and respect. Pursuant to California Civil Code Section 1789.83(c)(2), we do not share your Personal Information with other companies or third parties for those parties’ direct marketing use, unless you allow us to do so.
If you are a European Union resident, the General Data Protection Regulation (“GDPR”) permits you to request certain personal information, to request certain personal information to be erased, or to request inaccurate personal information to be fixed. Such a request is subject to GDPR regulations, as well as local laws and regulations where applicable.
To make such a request, please send an email to firstname.lastname@example.org with the subject line “GDPR Privacy Request” or write us at:
RE: GDPR Privacy Rights
CJ ENM America, Inc. / KCON USA
1600 Rosecrans Ave., Bldg. 2A, Ste. 301
Manhattan Beach, CA 90266
We will do our best to respond to you as promptly as possible upon receipt such a request.
PUBLIC FORUMS ON THE PROPERTY
Please remember that information posted to message boards, blogs, and other forums on the website or app becomes public information. Users under the age of 18 should use extra caution when posting and should be careful not to disclose any Personally Information on areas of the website and app where such information may become public. We cannot guarantee that parties who have access to such publicly available information will respect your privacy. Accordingly, please exercise extreme caution when deciding to disclose your personal information in these areas.