Date Last Updated: 08/07/2023

A360 Media, LLC and Accelerate 360 (collectively, “we”, “us” or “our”) own and operate websites, mobile applications, and other digital, interactive services (collectively, the “Services”). This Privacy Policy (“Statement” or “Policy”) applies to the information we collect through our Services, unless the website, mobile application, or other digital, interactive service has a separate privacy policy, in which case that privacy policy will govern. This Privacy Policy, together with the Terms of Use posted on our Services, sets forth the general rules and policies governing your use of our Services. Depending on your activities when visiting our Services, you may be required to agree to additional terms and conditions.

For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations.  It does not include data excluded or exempted from those laws and regulations.  Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to us or our Services generally or in any specific context.

This policy describes:

1. YOUR CONSENT TO THIS STATEMENT
2. INFORMATION WE COLLECT
3. HOW WE MAY SHARE YOUR INFORMATION
4. EXERCISING CHOICE

5.    COLORADO, CONNECTICUT, AND VIRGINIA USERS’ RIGHTS

6.    NEVADA USERS’ RIGHTS

7. DO NOT TRACK
8. SHINE THE LIGHT
9. ACCESSING AND UPDATING YOUR INFORMATION
10. USERS LOCATED IN THE EEA, UK, AND SWITZERLAND
11. SECURITY OF PERSONAL DATA
12. RETENTION OF PERSONAL DATA
13. CHILDREN
14. OTHER SITES / LINKS
15. CHANGES TO THIS PRIVACY POLICY
16. HOW TO CONTACT US

1.            YOUR CONSENT TO THIS STATEMENT

You should read this Statement carefully, so that you understand our privacy practices.  By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement.  If you do not agree to this Statement, you may not use the Services.

This Statement applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data.  This Statement supplements these other notices and is not intended to override them.

Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use incorporated by reference into this Policy.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “How to Contact Us” section below.

2.            INFORMATION WE COLLECT

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties.  You can use some of the Services without providing any information other than what is automatically collected as described below. Please note that we may combine information regarding offline subscribers with information relating to online activities or activities relating to your activities on the websites of our affiliates or partners.

Categories of Information We Collect

The categories of personal information that we may collect and the purposes for which we collect that information are described below.

• Account Information includes name, email address, username and password, gender, and date of birth.  We collect this information when you provide it directly to us.  We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Analytics Information.  We collect certain analytics information automatically as you navigate our Services.  This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails. This information is collected automatically based on your interactions with our Services.  For more information, please view the “Automatically-collected information” section below.  We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.

• Contact Information includes name, email address, and phone number. We collect this information when you provide it directly to us such as signing up for newsletters, requesting information about A360 products, creating an account, or filling out a form.  We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Commercial History includes information regarding the purchases you have made through our Services and your subscription information.  We may combine this information with other categories of information and disclose it to our affiliates, partners, and service providers for analytics, advertising, and marketing purposes. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.

• Payment Information includes name, address, phone number, and debit or credit card information.  We collect this information for the purposes of account creation and management, analytics and research, customer service, and website security and maintenance.
• Responses to Surveys and Questionnaires includes any information you provide to us when you voluntary complete market research surveys, such as email address, information regarding your interests, demographic information, and any other information you may provide to us.  We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Responses to Sweepstakes, Contests, or Promotions includes any information that you provide to us when you voluntarily enter into one of our promotional offerings.  This may include your contact information, analytics information, and any additional specific information identified at the time of collection. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Social Media Information includes information that you post by sharing on a blog or another social media platform.  We may also collect this information when you use a social media platform to log into our Services. We collect this information when you provide it directly to us or when you instruct another party to provide it to us directly.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.  We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance
• User-Generated Content.  If you post, upload, comment, or otherwise submit content on the Services, we may collect certain information about you such as your name and email address and products you may have purchased.  Be aware that as a default, any information you post on the Services, including without limitation review, comments, and text, may be available to and searchable by all users of the Services.  We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.

Purposes for Collection of Personal Information

The following chart identifies the purposes for which we may collect your personal information, as well as information regarding our use and disclosure of that personal information.  Please note that we may not collect each category of information about each user of our Services.

Other Ways We May Collect, Use, or Share Your Information

We also reserve the right to collect, use, or share personal information for the following purposes:

• For legal purposes.  We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on the Site.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.

• Business transactions or mergers.  We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.  Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence.  If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• Bankruptcy or insolvency.  In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
• Information from our partners and third-parties.  We may collect information from our partners such as market research firms and our affiliates, subsidiaries, joint ventures, or other companies with whom we operate.  We may combine that information with other information we collect about you, but we will always use the information as described in this Policy.  We collect this information for the purposes of marketing, advertising, research, and analytics.

Automatically-collected information

Device/usage information

As described above, we may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. We may combine this information with the other categories of information we collect about you, as described above.  As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.

We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique identifier for our internal use.

Location information

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. By using our Services, you consent to the collection of location information.

If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

Cookies and Local Stored Objects

To enhance your experience on our Services, we place “cookies” on your computer or device. Cookies are small text files that we place in your computer or device to store your preferences. Other information you provide to us may be linked to the data stored in the cookie. A cookie assigns a unique numerical identifier to your Web browser or device, and may enable us to recognize you as the same user who has used our Services, and relate your use of the Services to other information about you.

We use session and performance cookies to provide you with the services you request and to improve your experience with our Services. For example, we use cookies to personalize your experience on our Services (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, to enable shopping carts, or to tailor content or product and service offerings). Other cookies are essential to ensure the security and operation of our Services.

We also use cookies (and Local Shared Objects, HTML5, cache cookies, web beacons, or clear gifs, all described further below) to understand usage of the Services, analyze traffic, and to improve our content and offerings.

Some third parties, such as Google, may place cookies on your browser when you use our Services in order to track your activity across websites and to provide you advertisements tailored to your interests and online activities. For more information on how to opt out of Online Behavioral Advertising, see the Exercising Choice section below. For our European based users, we only place or allow tracking cookies to be placed on your browser with your consent.

Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser.

LiveRamp

When you use our website and enter your email address on our website (either to log in, or to sign up to a newsletter, or similar), we may share with LiveRamp and its group companies information that we collect from you, such as your email (in hashed, pseudonymous form), IP address, or information about your browser or operating system, with any of the following, acting as “joint controllers” (as applicable and defined in the GDPR).

LiveRamp uses this information to create an online identification code that we may store in our first-party cookie for our use in online, in-app, and cross-channel advertising. This may be shared with advertising companies to enable interest-based and targeted advertising. LiveRamp uses this information to create an online identification code for the purpose of recognizing you on your devices. This code does not contain any of your directly identifiable personal data and will not be used by LiveRamp to re-identify you.

Detailed information on LiveRamp’s data processing activities is available in LiveRamp’s privacy policy https://liveramp.com/privacy/. You have the right to withdraw your consent or opt-out to the processing of your personal data at any time. https://liveramp.com/opt_out.

Common ID Cookie

One of the cookies we use is the Common ID Cookie, which helps us provide our services and measure advertising effectiveness. The Common ID cookie stores a unique user id in the first party domain and is accessible to our ad partners. This simple ID that can be utilized to improve user matching, especially for delivering ads to iOS and MacOS browsers. Users can opt out of the Common ID tracking cookie by clicking here.

FOR EU USERS ONLY: When you use our site, pre-selected companies may access and use certain information on your device and about your interests to serve ads or personalized content. You may revisit or change consent-choices at any time by clicking here.

How to Manage Your Cookies

Please see our Cookie Policy for more information regarding how to disable, opt out, and otherwise manage cookies.  You can also find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

Aggregate or de-identified data

We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

3.            HOW WE MAY SHARE YOUR INFORMATION

We will make your information available to other companies, websites, applications or people with your consent, or consistent with our legitimate interests, in the circumstances described below:

• We may combine and share your information with non-affiliated third parties: (a) in order to provide services or products that we believe may be of interest to you; (b) when we have your permission; or (c) as described in this Privacy Policy.
• We may combine and share your information with our agents or companies in order to provide the Services or advertising or to communicate with you on our behalf.
• When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, and/or sponsors and the use of that information will be also governed by the privacy policies or practices of those advertisers, operators, and/or sponsors.
• We may combine and share your information with third-parties with whom we have a contractual relationship, including without limitation third party marketing partners for commercial purposes, third-party advertisers and advertising networks.
• We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose.

4.            EXERCISING CHOICE

Promotional Emails

You may opt-out from receiving future promotional emails from us, or direct that we not share your information with any Affiliated Companies, by clicking the “unsubscribe” button that appears on our promotional e-mails. Please refer to the settings or options menu in your email client for more information. You can remove yourself from our postal mailings by emailing us at privacy@a360media.com. You can also remove yourself by contacting us as described in the “How to Contact Us” section below.

Online Behavioral Advertising

When you use the Services, we may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us as described in this Policy.

Some of the services and advertisements are delivered or served by third-party companies. These companies place or recognize cookies, pixel tags, web beacons or other technology to track certain information about our Services website users. For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique cookie on your browser in order to collect certain information about your use of the Services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests.

We do not have access to, nor control over, these third parties’ use of cookies or other tracking technologies or how they may be used.

For example, we use Google to serve advertisements on the Services, which use the Google Doubleclick cookie, and in some cases, a unique device identifier, to show you ads based on your visit to our websites and other sites on the Internet. You may opt out of the use of the Google Doubleclick cookie by visiting the Google ad and content network privacy policy.

If you would like more information about this practice, and to learn how to opt out of behavioral advertising on the particular device on which you are accessing this Privacy Policy, please visit: https://optout.aboutads.info/ and https://optout.networkadvertising.org/?c=1.

You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in mobile apps.

Please note that the opt out is cookie-based and will only affect the specific computer and browser on which the opt out is applied. If you delete your browser cookies and want to continue to be opted out of interest-based ads, you will need to opt out again.

For more information about how we use cookies please visit our Cookie Policy.

Precise Device Location Tracking

If you authorized us and/or our service providers to collect and/or share information about the precise location of your device through a mobile application, you can always withdraw your consent and prevent the further collection and sharing of your precise device location information by accessing your devices location privacy settings. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to turn off precise location sharing. Access the privacy settings for your mobile device or contact your platform operator for more information.

5.            COLORADO, CONNECTICUT, AND VIRGINIA USERS’ RIGHTS

Colorado, Connecticut, and Virginia residents have certain rights with respect to their data.  These rights are established through the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).  The chart below explains these rights and lists the states whose residents may exercise those rights. 

Sensitive Information

Sensitive Data as defined in the CTDPA and VCDPA includes precise geolocation information.  For the purposes of serving you relevant advertisements based on your location, we collect geolocation information to perform geofencing.  We will not collect this information from Connecticut and Virginia residents without first obtaining consent.

Exercising Your Rights

If you are a Colorado, Connecticut, or Virginia resident and wish to exercise one of the above rights as it may apply to you, you can contact us by email at privacy@a360media.com or by phone at 800-929-8274.

If necessary, we may request additional information reasonably necessary to authenticate you and your request. 

In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights. 

We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay.  If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay. 

We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside.  We may charge a fee in:

• Colorado or Connecticut if you make more than one request in a twelve-month period; and
• Connecticut and Virginia, if the request is manifestly unfounded or excessive, or repetitive in nature.

Appealing a Rights Request Decision

If you are a resident of Colorado, Connecticut, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision.  To do this, you may email us at privacy@a360media.com. In the email appeal, please specify the right(s) you requested to exercise and the date you made such a request. 

We will inform you in writing within 45 days of any action taken or not taken in response to the appeal.  We will also provide a written explanation of the reasons for our decisions regarding your request(s).

6.            NEVADA USERS’ RIGHTS

Under Nevada law, certain Nevada consumers may opt out of the sale of certain personally identifiable information for monetary consideration to a person for that person to license or sell such information to additional persons. We do not accept any monetary compensation for data that we share.

If you are a Nevada resident who has purchased or leased goods or services from us, you may (A) submit a request to opt out of any potential future sales, and/or (B) request changes to your Covered Information by emailing us at privacy@a360media.com.  Please note we will take reasonable steps to verify your identity and the authenticity of the request.

7.            DO NOT TRACK

At this time, we do not recognize or respond to browser-initiated Do Not Track signals with the exception of the Global Privacy Control for residents of California, Colorado, Connecticut, and Virginia.

8.            SHINE THE LIGHT

Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law (if any) during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing at: privacy@a360media.com with the subject heading “California Privacy Rights.”

9.            ACCESSING AND UPDATING YOUR INFORMATION

You may contact us as at privacy@a360media.com if you have questions or comments about our Privacy Policy; wish to make corrections to any personally identifiable information you have provided; wish to request deletion of your personally identifiable information; want to opt-out from receiving future commercial correspondence, including emails, from us or our Affiliated Companies; or wish to withdraw your consent to sharing your personally identifiable information with others.

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services.

10.       USERS LOCATED IN THE EEA, UK, AND SWITZERLAND

If you are a user in the EEA or Switzerland, the following information applies with respect to personal data collected through your use of our Services.

Purposes of processing and legal basis for processing

We process personal data consistent with our disclosures in this Privacy Policy. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; (3) to meet legal obligations, and (4) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy. When we process your information on the basis of consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

Transfers

Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or processors maintain facilities. We have put in place appropriate safeguards to ensure the protection of any personal information transferred from the EEA, UK, or Switzerland to the United States and other countries. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy. To obtain more information regarding the safeguard(s) in place, please contact us using the information provided below.

Individual Rights.

If you are a resident of the EEA or Switzerland, you have certain rights under EU General Data Protection Regulation, as set forth below:

• Right of access: You have the right to request a copy of the information that we hold about you.
• Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected.
• Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.
• Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information.
• Right to withdraw consent: If you have provided consent for the processing of your information, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
• Right of portability: In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.
• Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling.
• Right to lodge a complaint: You have the right to lodge a complaint with a regulatory authority, if you believe that we have not complied with the requirements of the GDPR with regard to your personal information. A listing of EU data protection authorities can be located at: https://ec.europa.eu/justice/article-29/structure/data-protection-author…
• Right to object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).

This Privacy Policy does not create rights enforceable by third parties.

If you would like to exercise the above-mentioned rights, please direct your written concerns to the following address: privacy@a360media.com.

11.       SECURITY OF PERSONAL DATA

We maintain administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, loss, modification, disclosure, and any form of unlawful processing of personal data in our custody and control, and our service providers are bound to maintain similar safeguards. These measures also aim at preventing unnecessary collection and further processing of personal data. Although we take appropriate measures to safeguard the personal data in our custody and control, and we require similar safeguarding measures from our service providers, we need you to understand that we are unable to guarantee the security of your personal data.

To provide you with an increased level of security online, access to your personal data on certain of our websites may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication.

12.       RETENTION OF PERSONAL DATA

We will take reasonable steps to accurately record the personal data that you provide to us and any subsequent updates. We will retain your personal data as long as necessary to fulfill the purposes for which it was collected. Thereafter, we will either delete your personal data or de-identify it so that it cannot be attributed to your identity. Please note that we may continue to retain personal data for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

13.       CHILDREN

The features, programs, promotions and other aspects of our Services requiring the submission of personally identifiable information are not intended for anyone under 18 years of age. We do not knowingly collect personally identifiable information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe they have disclosed personally identifiable information to us, please contact us at privacy@a360media.com. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s personally identifiable information as well as prohibit its use.

14.       OTHER SITES/LINKS AND EMBEDDED CONTENT

Our Services may link to or contain links to other third party websites that we do not control or maintain, such as in connection with purchasing products referenced on our Services and banner advertisements. We are not responsible for the privacy practices employed by any third party website. We encourage you to note when you leave our Services and to read the privacy statements of all third party websites before submitting any personally identifiable information.

Please note that we may use embedded content on our website. Embedded content allows you to access a third party websites directly through a window in our Services.  To the extent that you interact with embedded content through our Services, the providers of such content may collect your personal information pursuant to the terms of their individual privacy notices.

15.       CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy. When we change it, we will make a copy of it available to you by posting it at www.a360media.com, or through other methods. If we make material changes to this Privacy Policy, we will make you aware of them where we post the updated policy and may also notify you by other reasonable methods that we select. If we make material changes to this Privacy Policy that will result in a new use, disclosure, or permission of access to your personal data that we previously collected and stored, we will obtain any consent that may be required by law.

You understand and agree that if you use this website after the effective date of the updated Privacy Policy, we consider your use as acceptance of it.

16.       HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, or other Privacy-related matters, you may contact us by email at privacy@a360media.com, by phone at 800-929-8274, or by mail at 1955 Lake Park Drive, Suite 400, Smyra, GA 30080.