Comprehensive Privacy Policy for Stone City Digital Services

DEFINITIONS

As used in this Privacy Policy, these terms have the following meanings:

“Client Business” means a person or entity (and authorized end users of such person or entity) that enters an Order for Services, has access to Customer Center Powered by Dash, or signs up for an account to use some of our business tools.

“Customer Center Powered by Dash” means our Client Business portal through which we may provide campaign results and other digital marketing reports. A Client Business’ access to and use of the Customer Center Powered by Dash is governed by its agreement with Stone City Digital Inc.

“Visitor” means any person who visits the Websites seeking information about our business services (and not for any personal or household purposes, as we do not provide such offerings) or engages with us in connection with our marketing, recruitment, events, or other general business activities that we may conduct or that others conduct on our behalf, and who is not a Client Business or a Patron to a Client Business. 

“Patron” means a customer or a prospect of a Client Business who visits a Client Business Website and/or otherwise engages with the Client Business using our Services. For example, if you are a Client Business that offers home services such as house cleaning services, customers or prospects that come to a Client Business Website to learn about your services are defined as Patrons for purposes of this Privacy Policy.  As described below, we collect and process Patron information only on behalf of and at the direction of a Client Business.

“Order” means the agreement entered into by Stone City Digital Inc. through our LocaliQ business platform and a Client Business for Services.

“Personal Information” (or “Personal Data” as used in the “Individuals in the European Area (EEA) or UK” section below) means any information that identifies, relates to, describes, references, or is reasonably capable of being associated with an identified or identifiable natural person or household. 

“Services” means the online digital marketing Services and platforms offered by Stone City Digital Inc. as further described in our Terms. For the avoidance of any doubt, our Services are offered for business purposes, and not for any personal or household use. 

“Service Provider” means the entity which “Processes” Personal Information on behalf of the “Business” as those terms are defined by applicable privacy laws or regulations.  As described further herein, we are a Service Provider to Client Businesses through our partnership with LocaliQ.

“Social Media Platforms” means third-party platforms such as, but not limited to, Facebook, Twitter, Instagram, and SnapChat.

“Terms” mean the Stone City Digital Inc. marketing terms and conditions located at Terms. 

“CCPA” shall mean the California Consumer Protection Act of 2018, as amended by the California Privacy Rights Act of 2020), which requires certain notices and may provide certain rights, may be applicable as defined further below (see “For California Residents”).

VISITORS: PERSONAL INFORMATION WE COLLECT

This section applies to information that we may collect and process or that you may provide to us when you visit the Websites or engage with us in connection with our marketing, recruitment, events, or other general business activities that we may conduct or others may conduct on our behalf, both online and offline. 

As a Visitor, we may collect the following types of Personal Information about you and your business contacts as described below:

(A) Personal Information you provide to us,

(B) Personal Information we may automatically collect, and

(C) Personal Information we may receive from third parties.

The following is a list of the categories of Personal Information we may collect from Visitors over the last twelve (12) months, both online and offline. You may provide this information to us, we may automatically collect it, or we may obtain it from third parties. 

Personal Information you provide to us. 

When you interact with the Websites or directly with Stone City Digital Inc., such as at events, we may collect the information you provide. For example, we may collect Information from you when you use the Websites to contact us with questions about the Services or our company or respond to our marketing and promotional messages, such as subscribing to our email list or filling out an online form. If you attend a Stone City Digital Inc. event, such as a trade show, or interact with one of our sales representatives, we may ask for Information from you in connection with such interactions. You may provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.

The Personal Information you provide may include:

• Business or other contact information (such as your name, telephone number, email address and mailing address);
• Professional information (such as your job title or company);
• Marketing information (such as your contact preferences), 
• Information through live chat and chatbots, or audio, such as voice recordings, that may be transcribed by us or a third party,
• Any other information you choose to provide to us; and 
• Information we may automatically collect: 

When you visit the Websites or use any tools on them, such as chat functionality, we use cookies and similar technologies, such as pixels and web beacons, to collect certain information automatically from your browser or device.

• The Information we automatically collect may include a session video recording, which may include details about how you use the Websites or tools, including, for example, how you engage and move around the pages (clicks, mouse hovers, and scroll behavior), pages viewed, time and date of visit, and duration of time on different pages or tools.
• The software you’re using, and other characteristics such as your web browser type, language, traffic source and operating system used, IP address, and identifiers associated with cookies or other technologies that may uniquely identify your browser.
• Device information, including the type of device you use, operating system version, and the device identifier. 
• Geolocation data, but only if shared with us through device settings.
• Pages you visited before or after navigating to or from the Websites and your activity there, including but not limited to any purchases or transactions made.
• We use cookies and other tracking technologies, such as pixels and plugins, as described in the Cookies and Other Tracking Technologies section below and in our Cookie Policy.
• Information we get from third parties. 

We may collect information from third parties, such as public databases, Social Media Platforms, third-party data providers, and our joint marketing partners, about you and your activities on and off the Websites.  Examples of this type of information include the ads you see and how you interact with them, the purchase and transactions you make, how you use third-party products and services, online or in person, and demographic information such as your professional or educational status.

VISITORS: WHY WE COLLECT AND HOW WE USE INFORMATION

We use the information we collect or you provide to us through the Websites and in connection with our marketing, recruitment, events, or other general business activities for a range of business purposes, including, without limitation:

• To develop, operate, improve, deliver, maintain, and protect the Websites and our marketing, recruitment, events, and other business activities.
• To better understand our Website Visitors and improve our Services, include using your information to: 
• Train our AI/ML Models: We may use the information we collect from you, your Patrons who engage with you using our Services, and publicly available information to help train our machine learning or artificial intelligence models, which we use to help us predict user preferences, for example. 
• Automated Analyses: We may review, scan, or analyze your communications with us, including, for example, via our email communications, for business and commercial purposes, including to improve or expand our product and services or to train our customer service or other employees. We may use artificial intelligence or automated methods for this purpose. 
• Automated Decisions.  You are not subject to decisions based solely on automated processing, including profiling, that produces legal effects concerning you. Automated checking of your geographical location may, however, be used to determine whether you are in the geographic scope of the services or products of the website operator. Automated processes are also used to review traffic through our system to detect and block spam, fraud, and other unlawful or undesirable activities.
• To respond to your online inquiries and requests and provide you with information and access to the resources or Services that you have requested from us.
• To provide a personalized experience to you, including by sending you marketing information, product recommendations, and communications (e.g., email, text messages, calls) about us in accordance with your marketing preferences, including information about our products, Services, promotions, or events.
• To conduct market research, advertise to you, and provide personalized or sponsored content based on your activities and interests.
• To carry out other legitimate business activities, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities.
• To identify you across multiple devices.
• To communicate with you, including marketing related messages or communications about our Services or those of our Business Clients, in response to your inquiries or questions, and for customer service and support purposes.
• To manage event registrations and attendance, including sending event-related communications to you.
• Register visitors to our offices for security reasons and manage nondisclosure agreements that Visitors may be required to sign. Process transactions and set up online accounts. Enhance the safety and security of the Websites and Services and protect against misuse or abuse of the Websites and Services.
• Comply with legal requirements and respond to lawful requests by public authorities.
• We may otherwise use your information with your consent or at your direction. 

VISITORS: HOW WE SHARE INFORMATION

See the General section below for ways we share your information.

CLIENT BUSINESSES: PERSONAL INFORMATION WE COLLECT

This section applies to the information we collect and process on behalf of or is provided to us by a Client Business in connection with the Services. This section refers to a Client Business, not a Visitor or a Patron.  We may collect the following types of Personal Information about you and your business contacts as described below:

(A)  Personal Information you provide to us,

(B)  Personal Information we may automatically collect, and

(C)  Personal Information we may receive from third parties.

1. Personal Information you provide to us.

    

When you interact with the Websites or Services or engage with us through other marketing, recruitment, events or business activities, we may collect information you provide.  In order to provide Services, we require our Client Businesses to provide us with information about themselves, their authorized end users, their Patrons, and their business.  This information may include:

• Applicable personal and business information and payment information (e.g., name, mailing address, email address, telephone number, date of birth, social security number (used only for verification purposes) bank account, debit or credit card number and associated contact information).
• Information about you to evaluate your credit worthiness, including your credit history, credit scores and other information provided by consumer reporting agencies such as your loan account or payment history; 
• Information about your authorized end users including name, email address, password, physical address, job title and phone number.
• Information about your Patrons, such as name, mailing address, telephone number, email address, and the products and services you provide to your Patrons. 
• Information you or your Patrons send through the Services or provide to us such as the content of a free-text entry box or SMS text on a Client Business Website and telephone calls to a Client Business.
• When you contact Stone City Digital Inc.’s customer support or communicate with us in any other way, we’ll collect whatever information you volunteer or that we need you to provide to resolve your question.
• We may collect information through live chat and chatbots, SMS text or audio, such as voice recordings, that may be transcribed by us or a third party.

1. Personal Information we may automatically collect.
   
   When you use the Services, we collect information about which Service features you’ve used and how you have used them. Additionally, when you interact with an email campaign that you receive from LocaliQ, we may collect information about your device and interaction with an email. If you are visiting our Websites or using any tools we offer such as chat functionality, we collect the same information described above in the Visitors section.  This information may include:

• A session video recording which may include details about how you use the Websites, or tools including, for example, how you engage and move around the pages (clicks, mouse hovers and scroll behavior), pages viewed, time and date of visit, duration of time on different pages or tools.
• The software you’re using and other characteristics such as your web browser type, language, traffic source, and operating system uses. IP address; identifiers associated with cookies or other technologies that may uniquely identify your browser;
• Usage Information. We may collect information about how you use the Services, such as the dates and times you access the Services, the features and functions of the Services you use, and how you access the Services. We also collect information about the performance of the Services. 
• Device Information. We may collect information from and about the devices you use to access the Services. For example, we may collect information about your hardware and software, such as the hardware model, operating system version, device memory, unique device identifiers, browser type, and language. Location Information. When you use the Services, we may also collect information about your location, such as an IP address.  We may be able to determine from an IP address a user’s Internet Service Provider and their general geographic location. Location data may be used to route your traffic to the nearest regional server to reduce latency and improve your experience. 
• Sensitive Personal Information. We may collect information through live chat and chatbots or audio, such as voice recordings, that may be transcribed by us or a third party.
• Any information we collect about Visitors when visiting our Websites as a Client Business.

1. Personal Information we may receive from third parties.

    

• If you link the Services to a third party’s Services or platform, such as Google or a Social Media Platform, we may receive information from the other Services or platforms to provide certain features of the Services to you.  For example, if a Patron leaves a review on your Facebook page, you may use certain features within the Services to access, review, and respond to such reviews, and you thereby allow us to collect that and other information from your Facebook page.  
• You may choose to use features of the Services that are provided by third parties or partners of LocaliQ such as a vendor that provides a promotional email campaign on your behalf to Patrons. These third parties may share information with Stone City Digital Inc., such as verifying credit applications or when you provide information about your usage, transactions, and campaign results with the Services provided by that third party.
• To improve our Services, verify eligibility for credit, and personalize your experience, we may obtain information about you from third parties, such as, without limitation, public databases, credit verification companies, Social Media Platforms, third-party data providers, and our joint marketing partners.

CLIENT BUSINESSES: WHY WE COLLECT AND HOW WE USE INFORMATION

We use your Personal Information to provide the Services to you and for the reasons provided below.

• Develop, operate, improve, deliver, maintain, and protect the Services, and develop new products and Services for our other business purposes, including but not limited to analytics, research, and marketing.   
• For business purposes, including sending you communications, including by email or SMS text if you provide your mobile number for that purpose.  
• For marketing purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted out of receiving such communications. 
• We may use email to respond to support inquiries or to share information about our Services, promotional offers, or events that may interest you.
• Monitor and analyze trends and usage. For example, we may analyze the needs and activities of our Client Businesses and their Patrons to help us better serve them, and we may conduct research and analysis related to our business and Services.
• Collect opinions and comments regarding the Services and new Services.
• Enhance the safety and security of the Services.
• Verify your identity and prevent fraud or other unauthorized or illegal activity.
• Enforce our agreements and other usage policies.
• Comply with legal requirements and respond to lawful requests by public authorities.
• Bill and collect fees and charges owed to us by you to deliver the Services.
• To develop, operate, improve, deliver, maintain, and protect the Websites and our marketing, recruitment, events, and other business activities.
• To better understand our Website Visitors and improve our Services, include using your information to: 
• Train our AI/ML Models: We may use the information we collect from you and publicly available information to help train our machine learning or artificial intelligence models, which we use to help us predict user preferences, for example. 
• Automated Analyses: We may review, scan, or analyze your communications with us, including via our email communications, chat features, and chatbots, for the business and commercial purposes set forth above, including to improve or expand our product and services or to train our customer service or other employees. We may use automated methods where reasonably possible.
• Automated Decisions.  You are not subject to decisions based solely on automated processing, including profiling, that produces legal effects concerning you. Automated checking of your geographical location may, however, be used to determine whether you are in the geographic scope of the services or products of the Website operator. Automated processes are also used to review traffic through our system to detect and block spam, fraud, and other unlawful or undesirable activities.

CLIENT BUSINESSES: HOW WE SHARE INFORMATION

See the General section below for more ways we share your information. With respect to Patron data, we may share Patron data in accordance with your instructions in connection with the Services and with our third-party Services providers or business partners who help us deliver or improve the Services or who perform Services on our behalf.

PATRONS

This section refers to Patrons and not to a Visitor or a Client Business.

This section applies to the information we may collect and/or process about our Client Business Patrons in our capacity as a “Service Provider,” “data processor,” “business associate,” or such similar term as defined by applicable privacy laws or regulations.

We collect information about Patrons as instructed by the Client Business.  Generally, we require Client Businesses to have the right to collect, use and share your information before providing it to us. Data collected about or from Patrons by the Client Business is subject to the Client Business’ privacy policy. LocaliQ is not responsible for the privacy or security practices of the Client Business, which may differ from those set forth in this Privacy Policy.  This Privacy Policy does not cover any data you provide to a Client Business, but rather, Patron data is subject to the respective Client Business’ privacy policies and security measures.

If you are a Patron of a Client Business and have any questions about Stone City Digital Inc.’s processing of Patron’s Personal Information on behalf of the Client Business, we direct you to contact us. 

GENERAL: RETAINING AND DISCLOSING YOUR PERSONAL INFORMATION TO OTHER PARTIES

With respect to Patrons, we will disclose your Personal Information as instructed by the Client Business.  

With respect to a Client Business and Visitor, we may disclose your Personal Information to other parties, including:

Our affiliates:

• Partners, vendors, Service Providers
• Technology companies, analytics companies, and other third parties with whom we have business relationships.
• Government regulators
• Our legal advisors and parties involved in a legal process.
• To an entity involved in the sale of our business
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you.
• The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

DATA RETENTION

We retain Information provided by or collected from Client Business, Visitors, and Patrons for as long as is reasonably necessary to provide the Services, for the purposes outlined in this Privacy Policy based on the context in which you provided it, or for the duration required by law, whichever is the longer. 

Data Transfers: We may share the information we collect globally, both internally across our offices and externally, with our vendors, Service Providers, and third parties who may be located in different jurisdictions.  Data transfers may be necessary to operate and provide the Services.  We have appropriate safeguards in place whenever we transfer your information.  

Anonymized, Aggregated, or De-Identified Information. As instructed by the Client Business, we may anonymize or aggregate information derived from Patrons. With respect to Client Business and Visitor data, we may anonymize, aggregate, or otherwise strip any Personal Information or other information we collect of all personally identifying characteristics so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, at our discretion. 

COOKIES AND OTHER TRACKING TECHNOLOGIES

Do We Use “Cookies”?

Yes. Cookies, SDKs, tracking pixels, and similar technologies are small files that Websites store on your device. These files recognize the user’s browser or device and capture and remember certain information.

In general, our third-party providers, advertisers, and marketing partners and we use these technologies on the Websites to optimize their functionality, help us understand how they are used, and provide users with interest-based content and/or advertising, including textual and/or audio-visual ads or content based upon their browsing activities and interests.   

With respect to cookies on a Client Business Website, we use technology as instructed by the Client Business and pursuant to our Terms. A Client Business may request that LocaliQ initiate campaigns that may require certain cookies on the Client Business Website to track browser or device information and build a profile of interests. The type of cookie placed on the Client Business Website depends on the type of Services the Client Business purchases from LocaliQ. For example, if a Client Business purchases ads on Social Media Platforms, cookies will be placed on the Client Business Website to collect ad performance metrics.  We are not responsible and disclaim all liability for data collected by third-party technologies that you authorize us to provide on a Client Business Website.

Please read our Cookie Policy for more information about the cookies and other technologies that we, our affiliates, third-party providers, and advertisers use on our Products.

In addition, you may opt out of certain interest-based advertising by using the following resources:

• You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
• You may opt out of receiving some permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
• You may opt out of having your activity on our Products made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser and visiting https://tools.google.com/dlpage/gaoptout.
• Global Privacy Settings.  The Global Privacy Control (GPC) signal allows users to opt out of certain types of tracking, including the sale of personal data, at the browser level instead of opting out at each individual website.  Currently, only certain browsers and browser extensions support the GPC (see https://globalprivacycontrol.org/ for a list of supported browsers and extensions).  We have used commercially reasonable efforts to configure our websites to respond to GPC signals when we detect them, and we make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.
• If you are a California or Virginia resident who is a Visitor or a Client Business, in order to exercise your right to opt out of targeted advertising or sales of your personal information, click on the “Do Not Sell/Share My Information” link on the bottom of the webpage where your information is being collected.

Note: Even if you opt-out, you will still see advertising; it just may be less relevant to you or personalized for you based only on the data that we have collected from you directly.

THIRD-PARTY LINKS

Our Websites may contain links to other websites, applications or Services that are not owned or controlled by us, including links to Social Media Platforms, or may redirect you off our Websites to other locations for information or other Services. This Privacy Policy only applies to information collected by us.  We are not responsible for the privacy and security practices of other website applications or Social Media Platforms or the information they may collect (which may include IP addresses or device identifiers). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other websites, applications, Social Media platforms, or content do not constitute or imply an endorsement or recommendation by us of the linked websites, application, Social Media Platform, and/or content.   No data collected by us or by third parties is 100% secure We use commercially reasonable procedures and various technical, administrative, and physical safeguards to help protect the confidentiality of Personal Information. 

However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. 

With respect to the security requirements of Client Businesses, we may provide for additional or different security measures in our agreements with them.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, please contact us promptly so that necessary measures can be taken.

ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION

If you are a Visitor or a Client Business and reside in California, you may exercise your privacy choices by submitting your request by following the directions as described below in Contact Us.  

If you are a Visitor or a Client Business, as required by applicable laws and subject to any permitted exceptions and limitations, you may exercise the following choices: 

• Access, modify, or delete the personal information we have about you
• Be informed of or receive an electronic copy of the personal information we have about you for data portability.
• Restrict, limit, or object to how we process certain personal information about you.
• You must submit a verified consumer request concerning your Personal Information to exercise these choices. Please submit a verifiable consumer request by following the directions as described below in Contact Us.  
• In some jurisdictions, you can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
• We’ll respond to your request in a manner consistent with applicable law, including any exceptions that may result in a request being denied in whole or in part.
• We might need to keep certain information for recordkeeping purposes.

CHILDREN PRIVACY

The Websites are not intended for use by children under 16. We do not knowingly collect Personal Information from anyone under 16. If we become aware that we have unknowingly collected Personal Information from a child under 16, we will make commercially reasonable efforts to delete such information from our database. 

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, WILL WE OR OUR SUBSIDIARIES, PARENT COMPANIES, OR AFFILIATES BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES THAT RESULT FROM OUR PROCESSING OR USE OF PERSONAL INFORMATION, EVEN IF WE ARE ADVISED BEFOREHAND OF THE POSSIBILITY OF SUCH DAMAGES.  THE MAXIMUM AMOUNT OF DAMAGES FOR WHICH WE WILL BE LIABLE UNDER THIS AGREEMENT WILL BE THE GREATER OF THE FEES YOU PAID FOR ANY PRODUCT IN CONNECTION WITH WHICH YOU PROVIDED YOUR PERSONAL INFORMATION, OR $100. (BECAUSE SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN CATEGORIES OF DAMAGES, THE ABOVE LIMITATION MAY NOT APPLY TO YOU. IN SUCH JURISDICTIONS, OUR LIABILITY AND THE LIABILITY OF OUR SUBSIDIARIES, PARENT COMPANIES AND AFFILIATES, IS LIMITED TO THE FULLEST EXTENT PERMITTED BY SUCH LAW.) 

IDEMNIFICATION

You agree to indemnify and hold harmless us, our affiliates, and each of our and their respective directors, officers, managers, employees, shareholders, agents, representatives, and licensors from and against any and all losses, expenses, damages and costs, including reasonable attorneys’ fees, that arise out of your provision of any inaccurate or unauthorized Personal Information to us, sending us Personal Information in violation of our Terms, or your violation of this Privacy Policy or any rights of another. We reserve the right to take over the exclusive defense of any claim for which we are entitled to indemnification under this section. In such event, you agree to provide us with such cooperation as reasonably requested. 

WAIVER OF CLASS ACTION CLAIMS

You and Stone City Digital Inc. agree that each party may bring disputes against the other party only in an individual capacity and not as a plaintiff or class member in any purported class or representative proceeding, including, without limitation, a federal or state class action lawsuit. However, nothing in this section limits your right or LocaliQ’s right to bring a lawsuit against each other as an individual plaintiff. This provision applies to the maximum extent permitted by applicable law to all claims that arise under, in connection with, or related to this Privacy Policy or the Personal Information you provide to us (whether your own or any other Personal Information you provide), Personal Information that is automatically collected by us and/or obtained by us from third parties; that arose under, in connection with, or relate to any previous privacy policy in effect or that otherwise arose before these terms went into effect; or that may arise in connection with or after or otherwise related to your Personal Information (or any other Personal Information you provide to us) after termination of any business relationship we may have with you, including cancellation or deletion of your accounts if applicable.

ACCESSIBILITY

If you experience any difficulty in accessing any part of the Websites or this Policy, contact us by following the directions below in Contact Us.  

CHANGES TO OUR PRIVACY POLICY

The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by posting a notice on the homepage of the Websites for a reasonable period of time after such changes are made that this Privacy Policy has been updated and by changing the “Last Modified” date at the top of this Privacy Policy, and for Client Businesses by sending you notice of the updates in the Customer Center Powered by Dash. We encourage you to periodically check this page and the Customer Center Powered by Dash for any changes. Your continued use of the Websites and our Services following the posting of changes to these terms will mean you accept those changes.

GOVERNING LAW

This Privacy Policy will be governed by and construed in accordance with the laws of the province of Ontario, without giving effect to any principles of conflicts of law. Stone City Digital Inc. makes no representation that this Privacy Policy and such practices comply with the laws of any other country. Visitors who use the Websites and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using our Websites, you consent to the transfer and use of your information outside your country.

SENSITIVE PERSONAL INFORMATION

Sensitive Personal Information is defined differently under different data privacy laws and may include, depending on the applicable law: 

• Government-issued IDs (such as your driver’s license, passport or social security number
• Your racial or ethnic origin
• Your political opinions
• Your religion or other beliefs
• Your health, biometric or genetic characteristics
• Any trade union membership
• Your sexuality (information about your sex life or sexual orientation)
• Any criminal background
• The content of your private communications (other than messages you may send to us) 
• GPS location is your precise geolocation and is considered a type of sensitive personal information.

We generally do not collect Sensitive Personal Information about you, and if we do, it is only for the purposes of providing services and goods to you, For example, if your business requested to be invoiced rather than paid by credit card, the credit application may ask for your Government-issued Ids otherwise as permitted by law. In other words, in limited circumstances, we may process Sensitive Personal Information as defined by applicable laws, but we do not use or disclose it other than for disclosed and permitted business purposes.

If you are a California Resident, you have a Right to Limit Our Use and Disclosure of Your Sensitive Personal Information for any purposes other than to provide the services or goods you request or as permitted by law. Additionally, your account access information, such as a username and password, may constitute Sensitive Personal Information under the CCPA, but we collect that information only for the accounts you create directly with us and to provide services and goods to you, and not for any other account you may have with a third party.  To opt out of additional purposes, follow the directions below in Contact Us.  (California residents only).

Visitors or Client Businesses

Applicability 

For purposes of this section, “Personal Information” has the meaning given in the (“CCPA”).  The following is a list of the categories of Personal Information we may collect from Visitors and Client Businesses who are California residents over the last twelve (12) months online and offline.  This information may be provided to us by you; we may automatically collect it, or we may obtain it from third parties. 

This does not mean that all examples of that category of Personal Information were, in fact, collected but reflects our good faith belief, to the best of our knowledge, that some of that information may have been collected about Visitors or Client Businesses. We will update this disclosure from time to time as appropriate.

Exclusions: For purposes of this section of the Privacy Policy does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Other information excluded from the CCPA’s scope, such as:
  • 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).
• Stone City Digital Inc. is a business and does not sell Personal Information. We may share Personal Information with third parties if they are authorized service providers or business partners who have agreed to our contractual limitations regarding their retention, use, and disclosure of such Personal Information. 

Rights to Know, Correction, and Deletion

You have a right to request that we disclose to you the Personal Information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such Personal Information. Note that we have provided much of this information in this Privacy Policy. You also have the right to request that we correct inaccurate Personal Information and delete Personal Information under certain circumstances, subject to several exceptions. See ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION above. 

Authorized Agents

You can designate an authorized agent to make a request to exercise your rights under the CCPA on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent

Non-Discrimination Rights

You may exercise any of your rights listed in this section without fear of unlawful discrimination. 

Record of Requests

We keep a record of requests that we received in a calendar year from California residents beginning on January 1, 2023. We will report the record of requests for the preceding calendar year by July 1 of the following calendar year.

CALIFORNIA DO NOT TRACK DISCLOSURES

“Do Not Track” (DNT) is a privacy preference you can set in your browser if you do not want online services to collect and share certain kinds of information about your online activity from this party tracking services.  For more information on Do Not Track, please visit allaboutdnt.com. 

CALIFORNIA “SHINE THE LIGHT” LAW/YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits consumers who are California residents to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, use the follow the Contact Us instructions described below.

INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA) OR UK

In the event Stone City Digital Inc. collects personally identifiable information from individuals in the EEA and UK through the Websites, it is the controller (as defined under the GDPR) for processing and using that Personal Data, the following rights will apply:

Rights of Individuals Based in the EEA or UK 

Subject to applicable law, you may be able to exercise any of the following rights in relation to your Personal Data:

• Right to know what information we have about you: This is known as the “right of access” and gives you the right to find out what, if any, Personal Data we have about you, how we process it, and to request a copy of the Personal Data.
• Right to correct your information: This is known as the “right of rectification” and gives you the right to ask that we correct or complete any Personal Data we have about you.
• Right to delete your information: This is known as the “right to erasure” or “right to be forgotten” and gives you the right to ask us to delete your Personal Data.
• Right to change how we use your information: This is known as the “right to restrict processing” and gives you the right to ask us to change how we use your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.
• Right to move your information: This is known as the “right to data portability” and gives you the right to ask to receive your Personal Data from us in a structured, commonly used, and machine-readable format or to have it transmitted to another controller.
• Right to stop us from using your information: This is known as the “right to object” and gives you the right to ask us to stop using your Personal Data when applicable.
• Rights relating to how we use your information to categorize you or make decisions about you: This is known as the “right in relation to automated decision-making and profiling.”: You have the right to be free from decisions we may make that are based solely on automated processing of your Personal Data, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.
• Right to withdraw consent: If we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This will not affect our use of your data before we receive notice that you wish to withdraw your consent.
• Right to file a complaint with the supervisory authority: If you are concerned about our privacy practices, including how we handled your Personal Data, you can report it to the supervisory authority authorized to hear those concerns in your jurisdiction. However, we invite you to contact us with any concerns, as we would be happy to try and resolve it directly.

You may exercise your rights by contacting us as indicated under the “Contact Us” section below. To change your consent settings for our use of cookies and other technologies, please see our Cookie Policy. 

The requests above will be considered and responded to in the time period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. 

CONTACT US

If you are a Visitor or Client Business and have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Information, your choices, and rights regarding such use, or you wish to exercise your rights, please contact us as provided below. 

Your Privacy Choices 

Write us at: Stone City Digital Inc, 100 – 623 Stone City Digital Inc., Kingston, Ontario, K7P 0L8 

Attn: Privacy Officer

Call us at 1 (386) 368.7960 (California residents only)