PRIVACY
Effective Date: February 1, 2019.
Introduction and Overview.
This Privacy Policy describes how Ella Rose Engine Works, Inc. (“EREW,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices about such use and sharing, and applies to your use of any online service location that posts a link to this Privacy Policy and all features, content, and other services that we own, control, and make available through such online service location (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).
By using the Service, you agree to our Terms of Use and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service.
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below.
Information Collection.
A. Information You Provide.
We collect information when you use the Service, including information you provide when you access our content, participate in a sweepstakes, contest, survey, or promotion (“Promotion”), or contact customer support. We may use Service Providers (defined below) to collect information.
The information we collect includes information that identifies you personally (whether alone or in combination). Some examples of information you provide include the following:
Contact Data, including your first and last name, email address, postal address, and phone number.
Demographic Data, including your age, gender, and country.
Content, including content within any messages you send to us (such as feedback and questions to customer support). or publicly post on the Service (such as in product reviews or blog comments).
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
In addition, we automatically collect information when you use the Service. Some examples of information we automatically collect include the following:
Service Use Data, including data about the features you use, the pages you visit, the emails and advertisements you view, the products you purchase, the time of day you browse, and your referring and exiting pages.
Device Connectivity and Configuration Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address, MAC address, and Ad Id (e.g., IDFA or AAID).
Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level) and, with your consent, precise location data (such as latitude/longitude data).
We use various current – and later – developed technologies to automatically collect information (“Tracking Technologies”), including the following:
Log Files, which are files that record events that occur in connection with your use of the Service.
Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
Pixels (also known as web beacons), which is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
Device Fingerprinting, which is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your browser and device.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, see the “Third Parties” and “Your Rights and Choices” sections below.
C. Information from Other Sources.
We also collect information from other sources. To the extent we combine third party sourced information with information we have collected through the Service, we will treat the combined information in accordance with the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources vary over time, but have included:
Social networks when you engage with our content, reference our Service, or grant us permission to access information from the social networks.
Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
For further information on Third Party Services, see the “Third Parties” section below.
3. Use of Information.
We use information we collect in accordance with the practices described in this Privacy Policy, including to:
Manage our Service, including providing access to the content.
Perform services requested by you.
Respond to your comments, questions, requests, and provide customer service.
Send you technical notices, updates, security alerts, administrative messages, and information regarding changes to our policies and support.
Prevent and address fraud, breach of policies or terms, and threats or harm.
Monitor and analyse trends, usage, and activities.
Conduct research, including focus groups and surveys.
Improve the Service or other EREW websites, apps, marketing efforts, products and services.
Develop and send you direct marketing, including advertisements and communications about our and third party products, offers, promotions, rewards, events, and services.
Conduct Promotions, including verifying your eligibility and delivering prizes in connection with your entries.
Serve advertising tailored to your interests on our Service and Third Party Services.
Fulfill any other purpose disclosed to you or with your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
4. Sharing of Information.
We share information we collect in accordance with the practices described in this Privacy Policy, including as follows:
Service Providers. We share information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as data analytics, marketing and advertising, website hosting, and technical support. Service Providers are prohibited from using information about you for any purpose other than to provide this assistance, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
Affiliates. We share information with our related entities including our parent and sister companies. For example, we share information with our affiliates for customer support, marketing, and technical operations.
Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
Facilitating Requests. We share information with third parties for purposes of facilitating your requests or enabling enhancements, such as when you choose to share information with a social network about your activities on the Service.
Promotions. If you voluntarily enter a Promotion, we share information with third parties as set out in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
Consent. We may share information to fulfill any other purpose disclosed to you or with your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) with third parties except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
5. Third Parties.
A. Third Party Services.
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service or a Third Party Service, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
B. Analytics and Interest-Based Advertising.
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics provides, such as Google Analytics, to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements on the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in emails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you on the Service and Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).
We serve ads on and through Third Party Services, such as Facebook and Google, that are targeted to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to the Third Party Service or incorporating a pixel from the Third Party Service on our Service, and the Third Party Service matching common factors between our data and their data. To opt-out of receiving Matched Ads, please contact the applicable Third Party Service. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such Facebook ads and find out how to opt-out. We are not responsible for such Third Party Service’s failure to comply with your opt-out instructions.
For further information on Tracking Technologies and your rights and choices regarding them, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
6. Your Rights and Choices.
A. Account Information.
You may access, update, or remove certain information that you have provided to us through by sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. California residents have additional rights as set out in the “Your California Privacy Rights” section below.
B. Tracking Technology Choices.
Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
C. Analytics and Interest-Based Advertising.
You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
Some of the third parties that collect information from or about you on the Service in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, http://www.aboutads.info/choices; and (ii) for mobile app opt-out, http://www.aboutads.info/appchoices. In addition, some of these third parties may be members of the Network Advertising Initiative ("NAI"). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
D. E-mail Communications.
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or EREW’s ongoing business relations.
Please note that your opt-out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
E. Your California Privacy Rights.
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt in to, or opt out of, this type of sharing.
EREW will not share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set out in the “Contact Us” section below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that EREW is not required to respond to requests made by means other than through the provided email address.
Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an email to the email address set out in the “Contact Us” section below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.
7. Children.
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. EREW does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe EREW has collected such information in a manner not permitted by COPPA, please contact us as set out in the “Contact Us” section below, and we will remove such data to the extent required by COPPA.
8. Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
9. International Transfer.
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.
10. Changes to this Privacy Policy.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates you consent and agree to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.
11. Contact Us.
If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:
By email:
info@ellaroseengineworks.com