Last Updated: December 1, 2020
1. INFORMATION COLLECTION AND USE
We collect information from you in several different ways on the Site. One goal in collecting personal information from you is to provide an efficient, meaningful, and customized experience. For example, we can use your personal information to:
(a) Registration and Purchasing. Before using certain parts of the Site or using our services, you may have to register. During registration, you will be prompted to provide to us certain personal information, which may include, but not be limited to, your name, mobile phone number, physical address, email address, social security number, date of birth and government-issued identification. These kinds of personal information are used to provide services to you in accordance with existing regulations, to assist third-party service providers to provide services to you, to communicate with you about our services and our Site, and for marketing purposes. If we encounter a problem when providing services, then we use the personal information to contact you.
(b) Email Addresses. Several locations of the Site may permit you to enter or for us to capture your email address for purposes including but not limited to: (i) registering for promotions, referral programs or services; or (ii) requesting us to notify you regarding particular promotions, referral programs or services. Your participation in a promotion or referral program is completely voluntary, so you have a choice whether to participate and disclose information to us. We use this information to notify promotion winners, pay referral fees and to award prizes.
(c) Cookies and Other Technology. Like many websites, the Site employs cookies, location-based services and web beacons (also known as clear GIF technology or “action tags”) to speed your navigation of the Site, recognize you and your access privileges, and track your usage.
(ii) Web beacons assist in delivering cookies and help us determine whether a web page on the Site has been viewed and, if so, how many times. For example, any electronic image on the Site, such as an ad banner, can function as a web beacon. We may also use web beacons to collect information about whether our electronic communications to our users have been delivered, viewed and opened. This data may impact the quantity and content of future communications from us to our users.
(iii) We may use third-party companies to help us tailor Site content to users or to serve ads or messages on our behalf. These companies may employ cookies and web beacons to measure advertising or messaging effectiveness (such as which web pages are visited, which messages are responded to, or what products are purchased and in what amount). Any information that these third parties collect via cookies and web beacons is not linked (by them) to any personal information collected by us.
(d) Log Files. As is true of most websites, the Site automatically recognizes the Internet URL or location from which you access the Site. We may also log your Internet protocol (“IP”) address, Internet service provider, and date/time stamp for system administration, order verification, marketing, and system troubleshooting purposes. An IP address may indicate the location of your computer on the Internet.
2. INFORMATION USE AND DISCLOSURE.
(a) Internal Use. We use your personal information to provide you with our services. We may internally use your personal information to improve the Site’s content and layout, to improve our outreach and for our own marketing efforts (including marketing our services to you), and to determine general marketplace information about visitors’ usage behavior to the Site.
(b) Communications with You. We will use your personal information to communicate with you about the Site, your use of our services, and new information available on the Site. Also, we may send you a confirmation email when you register with us or when you have completed a purchase or transfer that was requested through the Site. We may send you a service-related announcement on the rare occasions when it is necessary (for example, if we must temporarily suspend our service for maintenance). Also, we will send you a notification email or text message when you request us to notify you when particular services, promotions or referral programs become available or change. We always permit you to unsubscribe from promotional notifications. Because we have to communicate with you about our services that you choose to use, you cannot opt out of receiving emails related to those services or your account with us.
(c) External Use.
(i) We disclose information to our service providers to help enable them to perform services on your behalf. For example, in order for you to purchase and/or transfer and custody cryptocurrencies and other cryptoassets (collectively “virtual currencies”), we must share some information with third parties, such as your name, email address, physical address, social security number, date of birth, government-issued identification and the number of virtual currencies being purchased or transferred. Similarly, when we obtain bank account information for ACH transactions and credit card or debit card information, a third-party receives that information to process the payment in connection with the sale of cryptocurrencies. Even when you ask us to remember your bank account information, or credit card or debit card information, we do not store sensitive payment data such as the entire credit card number and CVC. Rather, we pass the payment data to the third-party processor and receive back from them a token that does not contain the sensitive data. We do retain non-sensitive payment data used to identify a payment such as the last four digits of a card number and expiration date.
(iii) We may be required to disclose certain information in response to requests from law-enforcement officials conducting investigations; subpoenas; a court order; or if we are otherwise required to disclose such information by law. We also will release personal information where disclosure is necessary to protect our legal rights, enforce other agreements, or to protect ourselves or others. For example, we may share information to reduce the risk of fraud or if someone uses or attempts to use the Site for illegal reasons or to commit fraud.
(iv) We may share non-personal information (such as the number of daily visitors to the Site or the size of an order placed on a certain date) with third parties. This information does not directly personally identify you or any user. For the avoidance of doubt, any IP addresses or a device or other identifier we collect may be shared with one or more third parties.
3. YOUR RIGHTS, CHOICES AND DISCLOSURES
(i) We provide herein certain specific disclosures on privacy rights set forth below. We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations. Although we may do so at our discretion, we do not delete your information upon request, unless required to do so under applicable law.
(ii) You may opt out of receiving electronic marketing communications from us by clicking next to the “unsubscribe” link on the communication or contacting us at email@example.com. Some non-marketing communications may not be subject to a general opt-out, such as fulfilling our obligations when services are requested and disclosures to comply with legal requirements, software updates and other support-related information.
(iii) Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
(iv) You may be able to disable Cookies through your browser settings, but if you delete or disable Cookies, you may experience interruptions or limited functionality in certain areas of the Services.
(c) California Disclosures.
(i) Pursuant to the California “Shine the Light” information-sharing disclosure requirements, California residents may request a list of all third parties with respect to which we have disclosed any information about you for direct marketing purposes and the categories of information disclosed. If you are a California resident and want such a list, please send us a written request by email to firstname.lastname@example.org with “California Shine The Light Rights” in the subject line.
(ii) Pursuant to the California Do Not Track disclosure requirements, we do not respond to Do Not Track browser settings.
(iii) Pursuant to the California Consumer Privacy Act (“CCPA”) disclosure requirements, California residents have the right to request:
Additionally, you have the right to request deletion of your personal information, the right to opt out of the sale of your information (if applicable) and the right not to be discriminated against for exercising any of your CCPA rights.
Our contact information, including a toll-free phone number, is listed at the bottom of this policy.
3. STORAGE OF DATA; DATA SECURITY
We retain the personal information we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store email addresses and phone numbers until the user requests to be unsubscribed or removes themselves through any self-service tools offered to the user.
The Site incorporates physical, electronic, and administrative procedures to safeguard the confidentiality of your personal information, including Secure Sockets Layer (“SSL”) for all transactions through the Site. We use SSL encryption to protect your personal information online, and we also take several steps to protect your personal information in our facilities. Access to your personal information is restricted. Only employees who need access to your personal information to perform a specific job are granted access to your personal information. Finally, we rely on third-party service providers for the physical security of some of our computer hardware. We require those third-party service providers to comply with commercially reasonable security practices and measures. For example, when you visit our Site, you access servers that are kept in a secure physical environment, behind a locked cage and an electronic firewall. While we use industry-standard precautions to safeguard your personal information, we cannot and do not guarantee complete security. 100% complete security does not presently exist anywhere online or offline. As such, you assume the risk of security breaches and all consequences resulting from them. To that end, please safeguard your credentials.
5. LINKS TO OTHER SITES
7. QUESTIONS AND CONTACT INFORMATION
Our mailing address is:
Return Network, LLC
1112 Montana Ave. #384
Santa Monica, CA 90402