Action AC Commercial

Information We May Collect About You and How We Collect It

We may collect several types of personally identifiable information from and about you including information that falls within the categories listed below. In addition, we have provided you with examples of personal information that we may collect, which corresponds with such categories.

Collectively, the information described above and any other personally identifying information we may collect from you shall be referred to as “personal information.” We may collect personal information:

• Directly from you if and when you provide it to us, including through the contact page on the Website, when you interact with the Website or other aspects of the Platform, through e-mail and subscription services, phone calls, if you order a product or service from us, or if you participate in an activity such as a survey or sweepstakes; and
• Automatically as you navigate through our Website through cookies and other automatic forms of data collection. Personal information collected automatically may include usage details, IP addresses, browser information and other information collected through automatic processes.

We ask that you do not send us or disclose any sensitive personal information on or through the Platform or otherwise. Such sensitive information includes racial or ethnic origin, religion or other beliefs, political opinions, health, criminal background or trade union membership.

Information We Collect through Automatic Data Collection Technologies

As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: 

• Details of your visits to the Platform, including traffic data, logs and other communication data and the resources that you access and use on the Platform; 
• Information about your computer, mobile device and internet connection, including your IP address, operating system, and browser type; 
• The approximate physical location of your computer and mobile device;
• The webpage that you may have linked to us from; and
• Search words or terms used on a search engine to link you to us.

 

The information we collect automatically is intended to be statistical data and may include personal information. It helps us improve the Platform, deliver a better and more personalized service, and ensure the Platform is secure and safe to use.

The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Cookies can be used to store a unique identification number tied to your device so you can be recognized as the same user across multiple browsing sessions and multiple websites.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of the Platform.  Unless you have adjusted your browser setting so that it will refuse cookies, we will issue cookies when you direct your browser to the Platform. You can opt out of receiving targeted advertising by visiting either of these outside websites www.aboutads.info or www.networkadvertising.org/choices. For more information on how we use cookies, please see our Cookie Notice.

California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings or signals. We do not currently take actions to respond to “Do Not Track” signals. It is our view that a uniform technological standard has not yet been developed.  We may adopt a standard once one is created. 

Information We Collect from Third Party Sources

We may also collect information about you from publicly and commercially available sources, as permitted by law, which we may combine with other information we receive from or about you. 

How We Use Your Personal Information 

We use information that we collect about you or your devices:

• To present the Website and other aspects of the Platform and its content to you;
• To provide you with information, products or services that you request from us;
• To fulfill any other purpose for which you provide it;
• To provide you with information regarding the services we offer, including new products and services that we may introduce from time to time;
• To notify you about changes to the Website or other aspects of the Platform or any products or services we offer or provide through it;
• To maintain and manage your account;
• To allow you to participate in interactive features on the Website or other aspects of the Platform;
• To conduct research on our users’ demographics, interests and behavior;
• To perform analyses or for other purposes to improve the quality of the Website, other aspects of the Platform, and our business;
• To publish our own marketing and promotional materials;
• To provide you with offers and information about the Website, other aspects of the Platform and our affiliates;
• To deliver targeted advertising, promotions and offers, on behalf of ourselves and advertisers, on and off the Website and other parts of the Platform;
• To process your requests, purchases, transactions and payments, and prevent transactional fraud;
• To ensure compliance across various segments of our business;
• To track and aggregate Website visitors’ and Platform visitors’ activity for purposes of analyzing general traffic flow on the Website and other parts of the Platform;
• In any other way we may describe when you provide the information; or
• For any other purpose with your consent.

We may also use your information to contact you, via your e-mail address or phone numbers, about our services that may be of interest to you.  If you do not want us to use your information in this way, please do not sign up for our subscription services.  If you have already received e-mails, phone calls or text messages through our subscription services, and you wish to discontinue the services, you may opt-out by following the instructions in our subscription e-mails or contacting us at [email protected].

Disclosure of Your Information

We may disclose personal information that we collect or you provide to third parties, including: 

• To contractors, service providers and other third parties we use to support the Website and other aspects of the Platform and our services and who are bound by contractual obligations to keep your personal information confidential;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred;
• To our affiliates and business partners;
• To third parties that provide advertising, content or functionality, or who analyze ad performance, on the Website, other parts of the Platform, or other websites or platforms;
• To common carriers and courier services;
• To product suppliers, including to fulfill warranty service obligations, complete drop ship transactions, for product recalls, or for transaction tracking regarding shipments of the supplier’s products;
• To fulfill the purpose for which you provide it;
• To publish our own marketing and promotional materials;
• If required by applicable law;
• If we believe disclosure is necessary or appropriate to protect our rights, property or safety and that of our customers or others;
• To comply with a judicial proceeding, court order, other legal obligation or a regulatory or government inquiry;
• For any other purpose disclosed by us when you provide the information; or
• With your consent.

We may disclose your personal information to a third party for business purposes. In the last 12 months, we have disclosed the following categories of personal information to the following categories of third parties:

Category A:	Identifiers
Category B:	Categories of personal information described in the California Customer Records Act
Category C:	Commercial information
Category D:	Internet or other electronic network activity
Category E:	Geolocation data
Category F:	Inferences drawn from personal information

 

When we disclose personal information for a business purpose, we enter into a contract that describes the business purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

You have the right to opt out of sales of your personal information. Although we do not expressly sell your personal information, we share your personal information with third party cookie providers through the use of cookies. In exchange, we (i) are able to provide more targeted marketing and advertising, which results in increased sales of our products and services; (ii) understand if the Website and other aspects of the Platform are functioning as intended, enabling us to refine the Website and other parts of the Platform, accordingly, potentially resulting in increased sales of products and services; and (iii) better understand the effectiveness of our marketing and advertising campaigns. For more information on how we use cookies, please see our Cookie Notice.

While we have not “sold” personal information as that term is commonly used, in the last 12 months, we have transferred the following categories of personal information to the following categories of third parties:

• Identifiers
• Internet or other electronic network activity

We do not knowingly sell the personal information of consumers under the age of 16.

The California Consumer Privacy Act of 2018 (the “CCPA”) prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Any third party with whom we are allowed to share your personal information is authorized to use your personal information in accordance with our contractual obligations with such third parties and in accordance with their own privacy policies, over which we have no control.  You agree that we are not responsible or liable for any of their actions or omissions.

If you provide personal information about another person to us, you will be representing, and we will believe, that you have the consent of that individual to enable us to collect, use or disclose their information as described in this notice, and will rely on our belief and your representation.

Update Your Information

You can modify your account with us by contacting us at [email protected]. Even after you cancel your account or ask us to delete your personal information, copies of some information from your account may still be viewable if, for example, you have shared information with other services such as social media. Your account may not be instantly inaccessible to others due to the nature of caching technology.  Additionally, we may retain information related to your account after cancellation or your request for deletion to comply with legal requirements, for our internal security or recordkeeping, or for fraud detection.  We may not be able to completely delete all of your personal information due to financial, contractual or legal requirements, or technical constraints. 

Your California Privacy Rights

Shine the Light Protection

California Civil Code Section §1798.83 permits users of the Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, if applicable.  To make such a request, please contact us at [email protected]. If you believe any of the information we possess about you is incorrect, please contact us at the same webpage listed above.

California Consumer Privacy Act of 2018

Consumers protected by the CCPA have specific rights regarding their personal information. 

Access to Specific Information

You have the right to request that we disclose to you the following about our collection and use of your personal information over the last 12 months:

• The specific pieces of personal information we collected about you.
• The categories of personal information we have collected about you in the last 12 months.
• The categories of sources from which the personal information was collected.
• The business or commercial purpose for collecting or selling personal information. 

• The categories of third parties with whom we share the personal information. 
• The categories of personal information that we disclosed about you for a business purpose in the last 12 months and, for each category identified, the categories of third parties to whom that particular category of personal information was disclosed for a business purpose.
• The categories of personal information that we sold about you in the last 12 months and, for each category identified, the categories of third parties to whom that particular category of personal information was sold.

We are not required to provide you with these disclosures more than twice within a 12-month period.  

For requests seeking disclosure of specific pieces of information, we will not disclose any such information if we cannot verify the identity of the requestor.  Similarly, for requests seeking categories of personal information, we may deny the request if we cannot verify the identity of the requestor. In either case, we will inform the requestor that we cannot verify their identity, and direct them to the general business practices regarding collection, maintenance and sale of personal information in our privacy policy.

If we deny your request for specific pieces of personal information, in whole or in part, because of a conflict with applicable laws or an exception to the CCPA, we will inform you and explain the basis for the denial. 

We will not disclose, even pursuant to a verifiable consumer request, a consumer’s social security number, driver’s license number, other government-issued identification number, financial account number, health insurance or medical identification number, account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. If applicable, we will notify you in response to a request for information that we have collected such information from you.

Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. Upon receipt of a verifiable consumer request to delete your personal information, we will delete such information and direct our service providers to delete your information from their records, subject to certain exceptions provided in the CCPA including, but not limited to, if it is necessary for us or our service providers to maintain the personal information in order to: 

(1) complete the transaction for which the personal information was collected, 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 us; 

(2) detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for that activity; 

(3) debug to identify and repair errors that impair existing intended functionality; 

(4) exercise free speech, ensure the right of another consumer to exercise his or her free speech, or exercise another right provided for by law; 

(5) comply with the California Electronic Communications Privacy Act; 

(6) 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, if you have provided informed consent; 

(7) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 

(8) to comply with a legal obligation; or 

(9) otherwise use your information, internally, in a lawful manner that is compatible with the context in which you provided the information. 

We use a two-step process for requests to delete personal information. First, you must make a verifiable consumer request. After receiving your request, we will contact you to separately confirm that you want your personal information deleted. We will contact you further once your personal information has been deleted.

If we cannot verify the identity of the person requesting deletion of personal information, we may deny the request and will inform the requestor we cannot verify their identity.  If we deny your request to delete personal information, we will notify you of the reasons why. We will delete any part of your personal information not covered by the exception allowing us to deny deletion of a portion of your personal information.

Non-Discrimination

If you are covered by the CCPA, we will not discriminate against you merely because you have exercised any of your rights under the CCPA.  Except as permitted by the CCPA, we will not, merely because you have exercised your rights under the CCPA, do any of the following:

• • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties;
  • Provide you with a different level or quality of goods or services; or

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Opt-Out Right

The CCPA defines “selling,” in part, as releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for monetary or “other valuable consideration.”  Under this broad definition, the sharing of personal information through the use of certain cookies could be interpreted as a “sale” of personal information.  Therefore, out of an abundance of caution, we provide you with the right to opt-out of the “sale” of your personal information even though such “sale” relates only to the use of certain cookies on our site. 

To that end, you have the right to opt out of the “sale” of your personal information by following the instructions on the “Do Not Sell My Personal Information” page or by contacting us at [email protected]. If you have opted-out of the “sale” of your personal information, we will wait at least 12 months before expressly asking you to reauthorize the “sale” of your personal information; though you will continue to have the ability to determine how certain cookies may be used on our Website or other parts of the Platform.  For more information on how we use cookies, please see our Cookie Notice.

You can use an authorized agent to submit your request to opt-out. Your authorized agent must have written permission to act on your behalf. If we believe a request to opt-out is fraudulent, we will notify the requestor that we will not comply with the request and provide an explanation as to why we think it is fraudulent. 

You can opt back in to the “sale” of your personal information at any time by contacting us at [email protected].  A request to opt-in is a two-step process.  First, you must clearly request to opt-in.  Then, we will separately confirm your choice to opt-in. In addition, as mentioned above, you will continue to have the ability to determine how certain cookies may be used on our Platform.

After opting in, you can once again opt-out by following the instructions on the “Do Not Sell My Personal Information” page or by contacting us at [email protected]

We do not knowingly sell the personal information of consumers under the age of 16.

Contact Information 

To request your right to disclosure or deletion of the personal information we have collected about you, please submit a verifiable consumer request to us by emailing us at [email protected]. If you have questions or concerns about our privacy policies or practices, please contact us at [email protected].

A verifiable consumer request can only be made by you, by you on behalf of your minor child, or by a person or entity registered with the California Secretary of State authorized by you to act on your behalf. In order to ensure we are able to promptly respond to your request, your request should include sufficient information that allows us to verify you are the person about whom we collected personal information or that you are an authorized representative of such person (including, for example, your full name, email address, and mailing address) and a detailed description of what you are requesting. We will review the identifying information provided in your request against information contained in our records to verify the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

If you are using an authorized agent to exercise any of your rights under the CCPA, you must provide us proof in the form of a signed, written authorization of the authorized agent’s ability to act on your behalf. You must also provide us with your full name, email address and mailing address to enable us to verify your identity.  We will confirm receipt of your verifiable consumer request within 10 business days of our receipt. We will also provide you with information about our verification process and when you should expect a response. 

We will disclose and deliver the personal information required within 45 days of receiving your verifiable consumer request.  Should we require more time (up to an additional 45 days), we will notify you of the extension and the reasons for the delay.  The disclosure will cover the 12-month period preceding the receipt of your verifiable consumer request.

If requests from you are manifestly unfounded or excessive, we may charge a reasonable fee to respond to your request or we may refuse to act on the request. If we choose not to take action on your request, we will notify you of the reasons behind our decision.

Children’s Privacy

Our services are not directed to, and we do not knowingly collect personal information from children under the age of 16.  If we receive personal information that we discover was provided by a child under the age of 16, we will promptly destroy the information. Please contact us immediately if you become aware that a child under 16 has provided us with personal information so that we may investigate and delete information as may be appropriate. We recommend that parents actively participate in their children’s use of the Internet.

Data Security

Unfortunately, the transmission of information via the Internet is not completely secure.  Although we implement reasonable measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Platform, or thereafter.  Any transmission of personal information is at your own risk.  It is important for you to protect against unauthorized access to your password and to your computer or mobile device.  Be sure to sign-off when finished using a shared computer or mobile device and use other reasonable measures to secure your sensitive information.

Links to Other Websites

We may provide (and permit other parties to provide) links to other websites or resources.  Because you acknowledge and agree that we have no control of such websites and resources, we are not responsible for the accuracy, reliability or availability of such websites or resources, and we do not endorse and are not responsible or liable for any content, advertising, products, information, data, opinions, advice, statements or other materials on or available from such websites or resources.  If you decide to access any of the third-party websites linked to our Platform, you do so at your own risk. Please read the terms and conditions and privacy policies of any other company or website you may link to from our Platform. You further acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, goods or services available on or through any such website or resource. Action AC reserves the right to terminate any link or linking program at any time. Action AC disclaims all warranties, express and implied, as to the accuracy, validity, and legality or otherwise of any materials or information contained on such sites.

You may not link to the Website or other parts of the Platform without Action AC’s prior written permission. If you are interested in linking to the Website or other parts of the Platform, please contact us at [email protected]. If you link to the Website or other parts of the Platform without our permission, you may be subject to IP address blacklisting.

How We Use Cookies and Similar Technologies

The Website (and other parts of the Platform) and third parties that provide content, advertising or functionality, or analyze advertising performance on the Website (and other parts of the Platform) may use cookies, mobile ad identifiers, web beacons and similar technologies to improve the Website (and other parts of the Platform), determine or improve the advertising shown to you here or elsewhere, to provide you with a personalized experience, or to facilitate administration and navigation of the Website (and other parts of the Platform). For more information on how we use cookies, please see our Cookie Notice.

Contact Information and Refusal to Consent

To ask questions or comment about this Privacy Policy and our privacy practices, including reviewing and requesting changes to any of your collected personal information, contact us at [email protected]. 

If you do not consent to the collection, use and disclosure of your personal information, please do not provide us with personal information.