Effective date: January 1, 2020
1. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect personal information when you use our Services. Personal information is any information that relates to you, identifies you personally, or could be used to identify you, such as your name, mailing address, email address, or telephone number.
The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site and services, information from third parties, and information received from other sources to help us supplement our records, improve the personalization of our service to you, and to detect fraud.
Information You Voluntarily Provide to Us
We may collect personal information from users who: purchase product from us; register a purchased product with us; review our products; participate in on-line surveys; wish to make certain on-line information requests from us; and/or from users who wish to participate in on-line contests, sweepstakes, promotions and discussions sponsored by us on this Site and mobile applications. The type of information so requested or collected by us may include user contact information (like their name, mailing address, and email address), billing information (like credit card number and expiration date) and user demographic information (like their zip code, age or income level). The visitor’s contact information will be used to contact the visitor when the visitor has expressed interest in being contacted (visitors may opt-out of receiving future mailings by emailing a request to us at email@example.com).
Information Collected Automatically
As you navigate through and interact with our Site or services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site, including, but not limited to, traffic data, location data, logs and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, the website that referred you to our website, and the subject of the ads you click or scroll over.
Information You Provide to Our Affiliates and Subsidiaries
We may get your personal information from a company controlled by or under common control with Citizen.
Information Collected from Other Sources
We receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.
- Some information we collect is publicly available. For example, we may collect information you submit to a blog, a chat room, or a social network like Facebook, Twitter or Google+. We may also collect information about you from other companies and organizations. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product recommendations and special offers that are more likely to interest you.
- We may use cameras in stores to keep employees and customers safe and to look for ways to improve our customer experience. We do not use these cameras to identify people except when necessary for security reasons.
2. COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Site or services, to make login to our Site or services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site or services, to enhance your experience with the Site or services, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site or services. The length of time a cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).
- Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some Services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.
- Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.
- Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. We do not use these cookies to target you with online marketing. You can disable these cookies.
- Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
We use Google Analytics on our web sites to collect usage data, to analyze how users use the web sites and to provide advertisements to you on other websites. For more information on the privacy practices of Google, please visit https://policies.google.com/privacy?hl=en. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
Other Tracking Technologies
We may also use tracking technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to us, and you can limit the communications that we send to you. In particular:
- Marketing Emails: You may choose to opt out of receiving commercial emails from us by following the instructions contained in any of the marketing emails we send. Please note that even if you unsubscribe from marketing email messages, we may still send you transactional emails related to your account or your purchases with us. You may update your subscription preferences at any time.
- Cookies and Other Technologies: You may manage how your browser handles cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt out of being targeted by certain ad-service companies and Citizen-served ads online by using the National Advertising Initiative’s Opt-Out Tool (http://optout.networkadvertising.org/?c=1) or the Digital Advertising Alliance’s (DAA) About Ads Opt-Out Tool (http://www.aboutads.info/choices/). In addition, your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies on our Site by taking the steps outlined below.
- First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly.
- Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies, visit http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
- Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage. Flash cookies are not managed by the same browser settings as are used for browser cookies, but may be managed here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android mobile device, you can change your device settings to control whether you see online interest-based ads.
We use internet and network activity information and device data to directly serve you ads on third-party websites and mobile applications. These ads will display the AdChoices icon. If you prefer not to receive ads from Citizen on third-party sites, you can click on the AdChoices icon in the ad, which will direct you to an AdChoices page where you can opt-out of receiving ads served by Citizen. Visit the DAA’s AdChoices page (https://youradchoices.com/) to learn more about interest-based advertising and to opt out of having cookies placed by ad-serving companies.
Currently, we do not alter our data collection and use practices in response to Do Not Track signals.
- Device Data: You may manage how your mobile device and mobile browser share certain device data, as well as how your mobile browser handles cookies by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. See your device settings for more information.
3. HOW WE USE YOUR INFORMATION
- To Provide You Our Services
We will use your personal information to provide information or perform Services that you request. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. Your information may be available or provided to third-party service providers and contractors that are contractually obligated to protect your information as disclosed in this Policy
- To Engage in Marketing Activities
Marketing lets us grow our community and update you about new products and services. We process your contact information or information about your interactions on our Services to: send you marketing communications and keep you updated about our products and services; provide you with information about events; and deliver targeted marketing to you. See Cookies and Other Tracking Technologies section of this Policy for more information about tracking techniques we use for our marketing campaigns.
- To Provide You with Service-Related Communications
We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
- To Provide Customer Support or Respond to You
We collect any information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
- For Internal Use
We will use your personal information for the purposes of furthering our business. For this purpose, we may monitor how our users use our Site including without limitation search terms entered, pages visited and documents viewed. This information may be stored with an IP address. This information is used solely for purposes of enabling us to provide you with a personalized Site experience.
- To Ensure the Security of the Services
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
- To Enforce Compliance with Our Terms and Agreements or Policies
- To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes and to fulfill our business obligations as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please use the contact information in the “Contact Us” section below to notify us of your opt-out preference.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
4. SHARING AND DISCLOSURE OF YOUR INFORMATION
If you choose to provide personal information, we may use it ourselves or share it with entities who provide services for us in connection with our Services. We do not otherwise share, sell, or lease personal information to any third parties for their marketing or other uses. We may disclose your personal information as described below.
- Service Providers
We may employ companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform Service-related services or assist us in analyzing how our Services are used. The Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- Within Our Corporate Organization
Citizen is a part of a corporate organization that has many legal entities, business processes, management structures and technical systems. Citizen may share your personal information with this organization to provide you with the Services and take actions based on your request.
- Corporate Transactions
- Third-Party Advertisers
In certain circumstances we may share your personal information with third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
- Co-Branded Services and Features
We may disclose your personal information for any purpose with your consent.
- Disclosure for Law Enforcement
We may disclose personal information to governmental authorities when legally required to do so, and may cooperate with such authorities investigating claims of illegal activities including, but not limited to, illegal transfer of copyrighted material, fraud, and/or postings or email messages containing threats of violence. Citizen may disclose your personal information in the good faith belief that such action is necessary to: comply with a legal obligation, protect and defend the rights or property of Citizen, prevent or investigate possible wrongdoing in connection with the Service. protect the personal safety of users of the Service or the public or protect against legal liability.
Please note that we may disclose, without restriction, aggregated or anonymized information about our users, which is information that does not identify any specific individual.
5. COMMUNICATION PREFERENCES
To provide our Services to you, we may send you communications related to your transactions, security, or the administration of our Services. From time to time, we may also send you other messages or updates about Citizen, our website, and promotions or other activities. If you do not wish to receive non-transaction/security related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or contact us where specified in the “Contact Us” section, below.
If you opt out of receiving communications from us, we may still send you service communications such as emails about your account, your purchases, or services we are providing to you. Please note that "opt-out" and "unsubscribe" requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.
Similarly, you may opt in to receive text messages, telephone calls and mailings. Where our mobile applications allow for the delivery of “push notifications” you can also opt out of receiving these notifications by toggling the “Notifications” switches within our mobile applications to “off.” By downloading and using our mobile applications, you may receive promotional messages, offers, news and information about Citizen within the mobile application itself. These “in app” messages are part of our mobile application’s functionality and cannot be turned off. If you do not want to receive “in app” messages, offers, news and information, do not download or use our mobile application.
6. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL INFORMATION
You have the right to access, correct and delete your personal information that you shared with us on our Site or by using our Services. We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You may notify us via the information in the “Contact Us” section below to request access to, or to correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you no longer wish to have your personal information processed, you may request to delete your account and the information in your account, subject to certain limitations, by emailing us as described below. Once you submit your request, we will send an email to the email address linked to your account requesting that you confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated personal information is deleted.
8. CALIFORNIA PRIVACY RIGHTS
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the Personal Information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information, and the third parties with whom we share your Personal Information:
- identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
- protected classifications, such as gender;
- commercial information such as records of products or services purchased, obtained, or considered by you;
- Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
- your geolocation, to the extent you have configured your device to permit us to collect such information;
- audio recordings of your voice to the extent you call us, as permitted under applicable law; and
- inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect education-related information. For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.
We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.
The categories of third parties with whom we may share your Personal Information are listed in Section 4, above.
If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.
- Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
- Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
- Right to Delete. You have the right to request us to delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions. To assert your right to know or your right to delete your Personal Information, please contact us according to the “Contact Us” section below. To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
9. DATA SECURITY
We take precautions to protect personal information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding your password and other information you share with us through our Services.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
10. INTEGRATION OF THIRD-PARTY PLATFORMS AND SERVICES
11. CHILDREN’S PRIVACY
Our Services are not intended to attract children under 18. Accordingly, we do not knowingly solicit or collect personal information from anyone we know to be under 18 years of age. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at firstname.lastname@example.org. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.
12. CONTACT US