Last Revised Feb 24, 2022
This policy is intended to comply with privacy laws that may apply to you, including without limitation the California Consumer Privacy Act of 2018 (“CCPA”) the General Data Protection Regulation, which applies across the European Union, the United Kindom General Data Protection Regulation (which, together with the E.U. General Data Protection Regulation are referred to collectively herein as the “GDPR”) and other privacy laws. For purposes of the GDPR, we are responsible as “controller” of that personal information for the purposes of those laws.
- Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”): Name, email, Address, Chalk Up Media, LLC purchase history.
This Personal Information is required to provide the Service to you. If you do not provide Personal Information we ask for, it may delay or prevent us from providing the Service to you.
- How Your Personal Information is Collected. We collect most of this personal information directly from you— via our website and MCU App, in person, by telephone, and/or text or email. However, we may also collect information:
- From publicly accessible sources (e.g., property records);
- Directly from a third party (e.g., credit reporting agencies, third party data brokers, or customer due diligence providers);
- From a third party with your consent (e.g., your bank);
- From cookies on our website; and
- Via our IT systems.
- How and Why We Use Your Personal Information. We may use the Personal Information we collect about you on its own or combine it with other information we have about you to:
- Perform internal operations, such as tracking and improving the effectiveness of our Service and marketing efforts;
- Provide product and/or Service fulfillment, such as managing purchases, payments, and more;
- Perform market research to learn about the interests and preferences of users;
- Personalize user experiences, such as remembering your settings and preferences for things like language, font size, etc.;
- Identify you as a user of the Service;
- Provide user support;
- Create, advertise and market new and existing products and services;
- Send newsletters, surveys, offers, and other promotional materials to you;
- Create user accounts and/or profiles through registration if and when we may require it;
- Notify you of security, or support and maintenance issues with the Service;
- Respond to inquiries related to the Service;
- Provide information to our representatives and/or advisors, such as our consultants, attorneys, accountants, and others to help us comply with legal, accounting, or security requirements;
- Protect the rights, safety, and information of Service users and third parties, as well as our own. This includes fraud prevention, business or product recalls, prosecuting and defending a court arbitration or similar proceeding, and more;
- Comply with legal requirements, such as in response to a subpoena or similar investigative demand; and
- Use for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
We may aggregate and/or anonymize all information that we collect from you, including Personal Information, for the purpose of market research on brands and products, marketing campaigns, and advertising, or for any other purpose, including disclosure to other third parties, as we may determine in our sole discretion.
Legal Bases for Use of Personal Information
The laws in some jurisdictions require businesses to tell you about the legal ground or basis that they rely on to use or disclose your Personal Information. To the extent those laws apply, our legal grounds for processing your Personal Information are as follows:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party, so long as they do not override the fundamental rights or freedoms of the relevant individuals, which legitimate interests may include, for example and without limitation, marketing, customer service; managing, analyzing and improving our products and services, and handling legal issues, among others;
- Where you have given consent.
- Promotional Communications. As noted above, we may use your personal information to send you updates (by email, text message, telephone or post) about our Service, including exclusive offers and promotions.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your Personal Information with the utmost respect and never sell or share it with another organization for that organization’s marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at [email protected];
- Using the “unsubscribe” link in emails; or
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
- Who We Share Your Personal Information With. We routinely share personal information with:
- Our affiliates;
- Service providers we use to help deliver our Service to you, such as payment service providers and information technology service providers;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Credit reporting agencies;
- Our insurers and brokers; and
- Our bank[s].
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your Personal Information. We may also share Personal Information with external auditors, e.g. in relation to audit of our accounts or business.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business, such as for a merger, sale of ownership or assets in the business, or during a re-structuring.
We will not share your personal information with any other third party.
- Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have not sold your Personal Information. In the preceding 12 months, we have disclosed for a business purpose to one or more third parties Personal Information from the category of “Identifiers,” described above.
- Where Your Personal Information is Held.Information may be held at our offices in the United States and those of our affiliates, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some or all of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
- How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing the Service to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law or our company’s data retention policies.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
If you would like further information, please contact us (see “How To Contact Us” below).
- Your Rights Under the GDPR.
|Right to Access||The right to be provided with a copy of your personal information (the right of access)|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information—in certain situations|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|Right to Object||The right to object: at any time to your personal information being processed for direct marketing (including profiling);in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.|
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
- Your Rights Under the CCPA.You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
|Disclosure of Personal Information We Collect About You||You have the right to know: The categories of personal information we have collected about you;The categories of sources from which the personal information is collected;Our business or commercial purpose for collecting or selling personal information;The categories of third parties with whom we share personal information, if any; andThe specific pieces of personal information we have collected about you.Please note that we are not required to:Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; orProvide the personal information to you more than twice in a 12-month period.|
|Personal Information Sold or Used for a Business Purpose||In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. As stated above, Morning Chalk Up does not sell your Personal Information. If you have any questions regarding our handling of your Personal Information, please contact us as set forth in the section titled “How to Contact Us” below.|
|Right to Deletion||Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; andDirect any service providers to delete your personal information from their records.Please note that we may not delete your personal information if it is necessary to:Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;Debug to identify and repair errors that impair existing intended functionality;Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;Comply with the California Electronic Communications Privacy Act;Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;Comply with an existing legal obligation; orOtherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.|
|Protection Against Discrimination||You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you;Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;Provide a different level or quality of goods or services to you; orSuggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.|
- Keeping Your Personal Information Secure. The security of your personal information is important to us. We have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. However, no method of transmission over the internet, or method of electronic storage is one hundred percent secure and we cannot guarantee its absolute security. Please contact us if you have any questions about security on our Service.
- Email us at [email protected].
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by email or phone, you will need to provide us with:
- Enough information to identify you;
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
- How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority in the U.K. or the European Union (or European Economic Area) member state where you work, normally live, or where any alleged infringement of data protection laws occurred.
- Children and Privacy. Our Service is not directed to persons under the age of 18. If you are not 18 years or older, do not use our Service. We do not knowingly collect Personal Information from persons under the age of 13.
- Do Not Track. “Do Not Track” is a type of privacy setting that web site visitors can set in certain web browsers. Morning Chalk Up does not currently recognize or respond to “Do Not Track” signals from browsers. To learn more about Do Not Track, click here.
- Third Party Web Sites and Services. Our Service may contain links to third party Services, applications and services not operated by us. These links are provided as a service and do not imply any endorsement by Localiti of the activities or content of these Services, applications or services nor any association with their operators. Additionally, our Service may include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Service. We are not responsible for the privacy policies or practices of any third party including Services or services directly linked to our Service. We encourage you to review the privacy policies of any third party Service that you visit.
- By emailing us at [email protected]
- By mail post to:
- Chalk Up Media Group LLC
358 Vuelo Street
New Braunfels, TX 78130
- Chalk Up Media Group LLC