Last updated: May 25, 2018

Information Collected Information You Provide: We collect information that you provide to us when you inquire about or purchase products and/or services through this Site. If you refuse to provide any requested information (whether or not required), you may not be able to take full advantage of this Site and its features. That information may include your (a) name, (b) address, (c) e-mail address, (d) telephone number, and (e) credit or debit card number.

In some cases, we may collect additional information you provide, such as your age, date of birth, gender, occupation, and education level. On our financial services Sites, with your consent, we may collect your Social Security number to verify your identity with a credit bureau and obtain your credit report and credit score. On certain Sites, we may also collect from you information about your contacts, such as their email address, to share an article or other content.

Information from Third Parties: We may also collect information about you from third parties, like credit reporting agencies or a social media site or a plug-in you use to log into or connect to this Site, and authorize to send us information from that social media account (e.g., name, age, photo). We may associate or combine the information you provide through this Site with this information collected from third parties.

Information Automatically Collected: When you use this Site, the server may automatically recognize you by a “cookie” or other tracking technology. These technologies act as unique identifiers and allow us to tailor this Site to your specified interests and keep track of your activity on this Site. This information may be added to your user profile and used to deliver offers and advertisements that we believe are relevant to your interests.

Furthermore, we may retrieve certain information from your browser (e.g., browser type, referrer URL, date and time of your visit, IP address) and device (e.g., MAC address, device type, screen resolution, and OS version). We use this information to monitor this Site’s performance, analyze traffic patterns and usage, ensure that this Site and any transactions function properly, and gather demographic information about our user base as a whole. This information also may be appended to your user profile so that we may further tailor this Site to your interests and send offers to you based on such information.

Our advertisers, publishers and other third-party partners also may utilize third-party cookies and other tracking technologies like clear pixel GIFs (i.e., web beacons) to identify you. We and our third-party partners may use these technologies to measure responses to e-mails and page views on this Site and our third-party partners’ websites. These technologies collect no personal information and are used to enhance this Site, to make this Site more relevant to you, and to measure the effectiveness of our e-mail and advertising campaigns and those of our third-party partners. You can opt out of some of our third-party partners’ use of cookies and other technologies at: https://www.google.com/settings/ads

Tracking Options and California Do Not Track Disclosures: Certain parts of this Site require cookies, and we may use them to deliver more relevant advertising and to link data collected across other devices you use. You can adjust your settings to limit tracking or decline cookies, but as a result you may not be able to use certain features of this Site or take full advantage of all of our offerings. Please refer to your device or browser settings for more information on how to delete or decline cookies and control your tracking preferences. This Site does not respond to do not track signals from most browsers.

Information Use

We may use the information we collect from and about you through this Site (a) to connect you with third-party partners who will provide information about products and services; (b) to respond to your inquiries and requests (e.g., newsletters); (c) to market to you and keep you informed of our products and services and/or those of our third-party partners, which we think may be of interest to you; (d) to develop new products and enhance and improve our Sites and business; (e) to complete and fulfill any purchase you make; and (f) to use your data in an aggregated, non-specific format for analytic and demographic purposes. Your contact information also may be used to reach you when necessary. With your consent, we may use automated decision-making, including profiling, to analyze the information collected from and about you.

We have a lawful basis for collecting and processing your information if (a) you consented to such processing; (b) we have a legitimate interest for processing your data, like analytics, fraud prevention, improving our Sites and our business, and direct marketing.

Information Sharing

Additionally, we may share your information (a) with other Businesses; (b) with third-party partners who will provide you with information about their product and services; (c) with our third-party service providers who provide services like payment processing, IT, and data analysis; (d) with national credit bureaus to verify your identity and obtain your credit report and credit score, where applicable; (e) if you seek insurance quotes, with financial services providers who offer competitive rates and/or the Department of Motor Vehicles to verify your driving record, previous claims history, and vehicle VINs; and (f) with a third party in the event of a sale or transfer of all or part of our business (including in connection with any bankruptcy proceeding).

We also may access and disclose your information to (a) comply with legal process; (b) to respond to lawful requests from authorities, including public and government authorities outside your country of residence, and including to meet national security or law enforcement requirements; (c) to enforce our terms and this Privacy Policy; (d) to protect our business; (e) to protect our rights, privacy, safety, or property and/or that of others; and (f) as necessary under applicable law, including laws outside your country of residence.

Other Websites

This Site may contain links to third-party owned and/or operated websites. We are not responsible for the privacy practices or the content of such third-party websites. These third-party websites have separate privacy practices; we have no responsibility or liability relating to such practices; and such practices govern your use of these websites. If this Site includes any mapping features, those mapping features are powered by Google Inc. and governed by Google’s privacy policy: http://www.google.com/privacy.html, as amended from time to time.

Security

We have taken certain physical, technical, and administrative steps to protect the information we collect from and about Site users. Please remember, though, that that neither the transmission of information over the Internet nor the storage of information can ever be 100% secure. If you have reason to believe that your interaction with us is no longer secure please immediately notify us at legal@acemedia.llc.

Children

We do not knowingly collect, use, or share the personal information of children under age 18 and this Site is not directed to individuals under 18. If we are made aware that we have collected personal information from an individual under age 18 we will delete this information as soon as possible.

Choices and Access

Additional Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our website has collected the following categories of personal information from its consumers within the last twelve (12) months:

CATEGORY	EXAMPLE	COLLECTED
A. Identifiers.	A real name, Internet Protocol address, email address, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO

Personal information does not include:

Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete on our website.
Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.

We may use, or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 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.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message.

We will only use personal information provided in an opt-out request to review and comply with the request.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at our address listed on our webpage.

Additional EU Disclosures

Legal Basis:We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
Where you have consented to a certain use of your personal data
Where we need to comply with a legal or regulatory obligation
To the extent permitted under applicable laws, we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.Data controller:Ace Media is the data controller of all personal data collected through our Web site. If you are situated in the EU and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you have a complaint, please contact our privacy manager at legal@acemedia.llc. Provision of personal data and failure to provide personal data:Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.Collection of Personal Information from third party sources: We also collect personal data about you from various third parties and public sources.Withdrawing your consent:If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at legal@acemedia.llcData Transfer: We may transfer personal data from the EU to the USA and other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. If we transfer personal data outside the EU to a processor, such transfer will be in compliance with the requirements of the GDPR.Use of your personal data for marketing purposes: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising: Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing. Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside of Three Ships and its related businesses for marketing purposes. To see how you can opt out of marketing communications, please see the section titled “Opt-Out”.Data Subject Rights: If you are a situated in the EU, under GDPR, as a data subject, you have the following rights:
- Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being process and provide access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data have been or will be disclosed and purposes of processing.
- Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
- Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
- Right to be forgotten – This right is also known as the “right to erasure”. It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
- Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
- Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

To exercise your rights under the GDPR, please contact us at legal@acemedia.llc. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.

Retention Period

We will retain your personal information for as long as is needed to provide you with our products and services, unless a longer retention period is required or permitted by law.

Operation of Our Site and Business

Our Site and business are operated in the United States. If you are located outside of the United States any information you provide to us will be transferred to and processed in the United States. By using this Site or providing us with your personal information, you consent to have your personal information transferred to and processed and stored in the United States in the absence of an adequacy decision or the appropriate safeguards set forth in Articles 45 and 46, respectively, of the General Data Protection Regulation.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. When we do, we will post an updated version of the Privacy Policy and revise the “LAST UPDATED” date at the top. If we change the Privacy Policy in any material way, we will endeavor to provide appropriate notice to you. Using this Site after any changes are made means you accept those changes and the revised Privacy Policy.

Businesses

For purposes of this Privacy Policy, “you” or “your” means the person(s) using this Site or the products or services offered through this Site. “Us,” or “we” or the “Business” includes (but is not limited to) Ace Media and its affiliates as the party responsible for the management of the jointly used information.

Dispute Resolution

You have the right to submit feedback about this Privacy Policy, or the practices described in it, to the applicable supervisory authority in your jurisdiction of residence. For U.S. residents this is/includes the Federal Trade Commission and/or your state Attorney General. For Non-U.S. residents this is/includes the Data Protection Authority in your country of residence.

Contact Us

If you have any questions about this Privacy Policy please contact us at legal@acemedia.llc.