THE REAL DILL, LLC PRIVACY POLICY

Last Modified: October 1, 2021

  

The Real Dill, LLC (the “Company”) understands the importance of your personal privacy. Therefore, we have created this privacy policy (this “Policy”) so that you know how we use and disclose your personal information when you make it available to us. This Policy discloses our practices regarding information collection and usage on the website located at www.therealdill.com, including any subpages (the “Website”). If you are accessing the Website on behalf of an organization or company, by your continued use of the Website you represent that you have the legal authority to bind any such organization or company to this Policy.

 

This Policy is an integral part of the terms of use that apply generally to the access and use of the Website found at [TERMS OF USE] (the “Website Terms of Use”). By using or accessing the Website, you signify your agreement to be bound by this Policy and the Website Terms of Use. If you are dissatisfied with this Policy, your sole and exclusive remedy is to cease your access to or use of the Website. IF YOU DO NOT AGREE TO ABIDE BY THIS POLICY AND THE WEBSITE TERMS OF USE, YOU MAY NOT ACCESS OR OTHERWISE USE THE WEBSITE.

 

Key aspects of our privacy practices described in this Policy include the following explanations:

 

• The information we collect and why we collect it;
• How we use that information;
• How we share information; and
• The choices we offer with respect to such information.

 

Personally Identifiable Information That We Collect

 

We may ask you for, or you may voluntarily submit, personally identifiable information when you are accessing or otherwise using the Website. The personally identifiable information which you may provide to us could include, but is not limited to:

 

• Your name;
• Your contact information (including, without limitation, address and email address);
• Your social media account information;
• Your IP address;
• Your use of and your activity on the Website; and
• Other personal information that could be used to identify you.

 

Changes To This Policy

 

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. However, if at any time in the future we plan to use personally identifiable information in a way that materially differs from this Policy, including sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the Website following the posting of any changes to this Policy means you accept such changes.

 

Non-Personal or Aggregate Information That We Collect

 

When you access the Website, we may automatically collect non-personally identifiable information from you. We may also aggregate demographic information collected from our users (such as the number of users in a particular geographical location) in a manner which does not identify any one individual. We may also aggregate information collected offline, obtain non-personally identifiable information from third party sources, and develop aggregate information by anonymizing previously collected personally identifiable information.

 

It is possible at times when collecting non-personally identifiable information through automatic means that we may unintentionally collect or receive personally identifiable information that is mixed in with the non-personally identifiable information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If you believe that we have inadvertently collected your personal information, please notify us at: [INSERT EMAIL ADDRESS].

 

Information Usage

 

We will only use your personally identifiable information as described below unless you have specifically consented to another type of use, either at the time the personally identifiable information is collected from you or through some other form of consent from you or notification to you:

 

• We may share your personally identifiable information collected in connection with your use of the Website.
• We may use your personally identifiable information to respond to your inquiries or requests.
• We may use your personally identifiable information to send you emails from time to time about our products and services, but we will not provide your personally identifiable information to third parties for them to contact you directly unless otherwise permitted by this Policy or you provide your consent.
• We may share your personally identifiable information with third parties (collectively, the “Third Party Vendors”) to further the purpose for which you provided such information to us. We urge you to read the privacy practices of all of our Third Party Vendors before submitting any personally identifiable information through the Website.
• We may share activity data of your use of the Website with third parties for advertising purposes, however, we will not share personally identifiable information for this purpose.
• We may disclose personally identifiable information as required by law or legal process.
• We may disclose personally identifiable information to investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, or the terms or policies for our products and services or our sponsors.
• We may transfer your personally identifiable information in connection with the sale or merger or change of control of the Company, or the division responsible for the services with which your personally identifiable information is associated.
• We may share personally identifiable information you provide to us to Company personnel who use this information in providing their services to you through the Website.

 

Non-personally identifiable or aggregate information may be used by us for any purposes permitted by law and may be shared with any number of parties, provided that such information shall not specifically identify you.

 

Cookies And Similar Technologies

 

“Cookies” are pieces of information that may be placed on your computer by a service for the purpose of facilitating and enhancing your communication and interaction with that service. Many services use cookies for these purposes. We may use cookies (and similar items such as clear gifs, web beacons, tags, etc.) on our Website to customize your visit and for other purposes to make your visit more convenient or to enable us to enhance our services. We may also use and place cookies (and similar items) on your computer or mobile device from our third-party service providers, such as an analytics provider that helps us manage and analyze Website usage, as described more fully below. In addition, our advertisers and business partners may set cookies and similar items when you use the Website. You may stop or restrict the placement of cookies or flush them from your browser by adjusting your web browser preferences, in which case you may still use the Website, but it may interfere with some of its functionality. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your computer without your knowledge. The Company’s Cookie Policy, which can be accessed here [ADD LINK TO COOKIE POLICY], provides more information on how we use cookies. You will also find information about how you can manage your cookie preferences and opt-out of certain types of tracking.

 

Analytics And Conversion Tracking

 

We may use analytics services that use cookies, JavaScript, and similar technologies to help us analyze how users use the Website. The information generated by these services about your use of the Website (including your internet protocol address (“IP Address”) or a truncated version of your IP address) is transmitted to and stored by analytics service providers on their servers. Those service providers will use this information for the purpose of evaluating your, and other users’, use of the Website, compiling reports for us on website activity and providing other services relating to website activity and internet usage.

 

We may collect information about your computer or your mobile device, including your IP address, operating system, and browser type, for system administration and for the purpose of creating informational reports. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. For example, we may use cookies on our site for Google Analytics (the “Analytics Service”), and we may also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Website. The Analytics Service is a web-based analytics tool that helps website owners understand how visitors engage with their website. The Analytics Service allows customers to view a variety of reports about how visitors interact with their website so that they can improve it. Like many services, the Analytics Service uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.

 

The Analytics Service collects information anonymously. They report website trends without identifying individual visitors. You can opt out of the Analytics Service without affecting how you visit the Website. For more information about how to opt out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.

 

Automatically Collected Information

 

When you access the Website or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include your IP Address, a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content, and pages that you access on the Website, the number of clicks, the amount of time spent on pages, the dates, and times that you visit the Website, and other similar information. Depending on the law of your country of residence, your IP Address may legally be considered personally identifiable information.

 

Security

 

The security of your personally identifiable information is very important to us. When we collect your personally identifiable information online, we use reasonable efforts to protect it from unauthorized access. However, due to the inherent open nature of the internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties. Your use of the Website demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information. For more information on protecting your privacy, please visit www.ftc.gov/privacy.

 

Your Disclosures in Blogs And Other Social Media

 

You should be aware that personally identifiable information which you voluntarily include and transmit on the Website or that you share in an open forum such as an in-person panel or survey or on social media, may be viewed and used by others without any restrictions. We are unable to control such uses of your personally identifiable information, and by using the Website or any other online services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties for any number of purposes.

 

Other Services

 

As a convenience to you, we may provide links to third-party services from within our Website. We are not responsible for the privacy practices or content of these third-party sites. When you link away from our Website, you do so at your own risk.

 

Protection For Children

 

We do not intentionally collect personally identifiable information from children under the age of 13. If at any time in the future we plan to collect personally identifiable information from children under 13, such collection and use, to the extent applicable, shall, when required, be done in compliance with the Children’s Online Privacy Protection Act (“COPPA”) and appropriate consent from the child’s parent or guardian will be sought where required by COPPA. When we become aware that personally identifiable information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database.

 

Your California Privacy Rights

 

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights under the California Consumer Privacy Act of 2018 (“CCPA”), visit https://oag.ca.gov/privacy/ccpa.

 

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.

 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the 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 an email to [INSERT EMAIL ADDRESS] or call us at [INSERT TOLL FREE NUMBER].

 

Communications With Company Processing Agents

 

By providing your contact information to us (including, without limitation, your email address, physical address, and phone number) (collectively the “Channels”) to us, you expressly consent to receive communications from us. We may use the Channels to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us or our business partners, provided that, we will not give your contact information to another party to promote their products or services directly to you without your consent or as set forth in this Policy. By using the Website, you expressly consent to receive in-product communications from us. By providing your phone number to us, you expressly consent to receive phone calls and/or text messages from us. MESSAGE AND DATA RATES MAY APPLY. We will not give your phone number to another party to promote their products or services directly to you without your consent or as set forth in this Policy. You are solely responsible for any carrier charges incurred as a result of a phone and/or text communications from Us.

 

Any communication or material you transmit to us by email or otherwise, including any data, questions, comments, suggestions, or the like is, and will be treated as, non-confidential and nonproprietary. Except to the extent expressly covered by this Policy, anything you transmit or post may be used by us for any purpose, including but not limited to, reproduction, disclosure, transmission, publication, broadcast, and posting. Furthermore, you expressly agree that we are free to use any ideas, concepts, know-how, or techniques contained in any communication you send to us, as well as any data developed using the content of such communication, without compensation and for any purpose whatsoever, including but not limited to, developing, manufacturing, and marketing products and services using such information.

 

Right to Know and Data Portability

 

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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete, below), 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.
• 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.
  • the specific pieces of personal information we collected about you (also called a data portability request).

 

We do not provide a right to know or data portability disclosure for written or verbal business-to-business communication (“B2B personal information”).

 

Right to Delete

 

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 (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 any applicable law or any legal obligation.
• 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.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. We do not provide these deletion rights for B2B personal information.

 

Exercising Your Rights to Know or Delete

 

To exercise your rights to know or delete described above, please submit a request by either:

 

• Calling us at [INSERT TOLL FREE NUMBER]
• Emailing us at [INSERT CONTACT EMAIL ADDRESS]
• Visiting [INSERT CONTACT WEBPAGE]

 

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may, however, make a request to know or delete on behalf of your child. You may only submit a request to know or delete for the same person twice within a 12-month period. 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 the request to verify the requestor's identity or authority to make it.

 

Your request to know or delete must:

 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, but shall not be limited to:
  • The type of information given.
  • Approximate dates when such personal information was requested.
  • Where the data was collected.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

 

Response Timing and Format

 

We will confirm receipt of your request to know or request to delete within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact us by email at: [INSERT CONTACT EMAIL] or call us at: [INSERT TOLL FREE NUMBER]. 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. We endeavor to substantively respond to a verifiable consumer request within forty-five days of its receipt. If we require more time (up to another forty-five days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, 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 our receipt of your request. 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.

 

No Rights of Third Parties

 

This Policy does not create rights enforceable by third parties, nor does it require disclosure of any personal information relating to users of the Website.

 

Site Terms of Use

 

Use of the Website is governed by, and subject to, this Policy and the Website Terms of Use. This Policy hereby is incorporated into and made a part of the Website Terms of Use by this reference. Your use or access of the Website constitutes your agreement to be bound by these provisions. IF YOU DO NOT AGREE TO THE WEBSITE TERMS OF USE AND THIS POLICY, YOU MAY NOT ACCESS OR OTHERWISE USE THE WEBSITE.

 

Servers

 

Our servers are maintained in the United States. By using the Website, you freely and specifically give us your consent to export your personally identifiable information to the United States and to store and use it in the United States as specified in this Policy. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States.

 

Governing Law

 

This Policy and our legal obligations hereunder are subject to the laws of the State of Colorado regardless of your location. You hereby consent to the exclusive jurisdiction of and venue in the courts located in the State of Colorado, County of Denver, in all disputes arising out of or relating to the Website.

 

Contact

 

For questions or concerns relating to privacy, you can contact us at:

Phone: [INSERT TOLL FREE NUMBER]

Website: [INSERT CONTACT WEBPAGE]

Email: [INSERT CONTACT EMAIL]

Postal Address:         The Real Dill, LLC

                                    PO Box 18104

Denver, Colorado 80218

 

If you need to access this Policy in an alternative format due to having a disability, please contact [INSERT CONTACT EMAIL] or [INSERT TOLL FREE NUMBER].