Privacy Policy

This Privacy Policy describes how SendSmiles, Inc. and our subsidiaries and affiliates (collectively "SendSmiles," "we", “us” or "our") handle personal information when you use our websites and other digital properties that link to this Privacy Policy (collectively, the “Site”), our mobile applications (the “App”), participate in our events or activities, receive our marketing communications, or engage with us on our social networks (collectively, the “Service”).

Personal Information We Collect

Information you give us. Personal information that you may provide through the Service or otherwise includes:

• Contact information, such as your first name, last name, professional title, organizational affiliation, postal address, office location, email address and telephone number;
• Profile information, such as information you provide when you respond to surveys, participate in market research activities, participate in telephone conferences with our representatives (which may be recorded with your permission where permitted by law); report a problem with Service, receive customer support or otherwise communicate with us;
• Transaction information, such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history;
• Marketing information, such your preferences for receiving marketing communications and details about how you engage with them; and
• Other information that you choose to provide but is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information from third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as our business partners, such as joint marketing partners and event co-sponsors; and publicly accessible sources, such as social media platforms.

Data collected automatically We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Site and other online services:

• Device data such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.
• Usage data, uch as the website you visited before browsing to the Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Precise geolocation data, such as when you authorize our mobile application to access your location.

Some of our automatic collection is facilitated by:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Software development kits, or SDKs, which are used to incorporate third party computer code into our App that allows our third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the App, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

How We Use Your Personal Information

We use your personal information for the following purposes or as otherwise described to you at the time of collection:

Service delivery. We use your personal information to:

• provide, operate, maintain, and improve the Service;
• communicate with you regarding the Service, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
• process your Service subscription transactions and process your related payments:
• understand your needs and interests, and personalize your experience with the Service; and
• provide support for the Service and respond to your requests, questions and feedback.

Site operation. We use your personal information to:

• provide, operate, maintain and improve the Site;
• understand your needs and interests, and personalize your experience with the Site; and
• provide support for the Site and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. If you request information from us, use the Service or participate in our surveys, promotions or events, we may send you SendSmiles-related marketing communications as permitted by law but will provide you with the ability to opt out.
• Interest-based advertising.We may contract with third-party advertising and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” section below.

Compliance and protection. We may use your personal information to:

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce our Terms of Use;
• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

Other purposes with your consent. In some cases we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.

How We Share Your Personal Information

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for use consistent with this Privacy Policy.
• Service providers We may employ companies and individuals to help provide the Site or Service on our behalf or help us operate our business (such as IT, customer support, hosting, website analytics, email delivery, marketing and advertising, research, event management). They are permitted to use your personal information only as authorized to perform these tasks in a manner consistent with this Privacy Policy.
• Payment processors Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Stripe Inc. (“Stripe”), and we never physically receive or store your full payment card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy here: https://stripe.com/privacy.
• Advertising partners. We work with third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.
• Compliance and protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.
• Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Access, Update, Correct or Delete Your Information. You may review, update, correct or delete your personal information in their account by emailing us at care@sendsmiles.com.

Marketing communications. You may opt out of marketing-related emails by following the opt-out prompt in the email. You may continue to receive Service-related and other non-marketing emails.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Privacy settings and location data. Users of our App can disable our access to their device’s precise geolocation in their mobile device settings.

Advertising choices. You can also limit use of your information for interest-based advertising by:

• Browser settings. Blocking third party cookies in your browser settings using or ad-blocking browser plug-ins/extensions.
• Mobile device settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Platform settings. Using Google’s and Facebook’s interest-based advertising opt-out features:
  
  
  • Google: https://adssettings.google.com/
  • Facebook: https://www.facebook.com/about/ads
• Ad industry tools.Opting out of interest-based ads from companies participating in the following industry opt-out programs:
  
  
  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance:
  
  
  • optout.aboutads.info, which lets you opt-out of interest-based ads on websites.
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which lets you opt-out of interest-based ads in mobile apps.

The opt-out preferences described above must be set on each device for which you want them to apply. Not all companies that serve interest-based ads participate in the ad industry opt-out programs described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Declining to provide your personal information. If you do not provide information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, that portion or all of the Service may be unavailable to you and we may deactivate your account.

Security

The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

International Data Use

SendSmiles is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.

Third Party Sites and Services

The Service may contain links to other websites and services operated by third parties, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and disclosure of your personal information. We encourage you to read their privacy policies to learn more.

Children

The Service is not directed at, and SendSmiles does not knowingly acquire or receive personal information from, children under the age of 13. If we learn that any user of the Service is under the age of 13, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Service.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will notify you by email (if you have an account linked to a valid email address) or another manner through the Service that we believe is reasonably likely to reach you. Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any updated Privacy Policy indicates your acceptance of the update.

Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us:
SendSmiles, Inc.
4212 Technology Court, Suite E
Chantilly, Virginia 20151
Email: care@sendsmiles.com