Privacy

Last updated July 3 2019

The website you have entered and specifically including its sub-domains, affiliated websites or applications, and any services available therefrom, including any mobile versions of the website or mobile applications) (the “Site”) is operated by Sfuso Inc. (“Sfuso Inc.” “we” or “us”). We respect your privacy rights and recognize the importance of protecting data collected from you and about you. This privacy policy (the “Privacy Policy”) describes how we collect, use, share, and protect that data.
If you do not accept and agree with this Privacy Policy, you must stop using the Site immediately. Your continued use of the Site constitutes your acceptance of this Privacy Policy.

1. Collection of Data
a. We collect personal data when you voluntarily provide it to us.
We collect personal data from you in several different ways on the Site. Personal data means information that can reasonably be used to identify you personally (such as your name, phone number, address, and email address). We collect this personal data when you voluntarily provide it to us (such as when you submit this information to create or open an account with us and join our customer list or when you submit an inquiry). You can choose not to provide the requested data, but you might not be able to take advantage of certain Site features.
You may post reviews of your purchases on our Site. You should be aware that, when you disclose information about yourself on the Site, the Site will collect the information you provide in such submissions, including any personal information. If you choose to submit content to any public area of the Site, such content will be considered “public”, and will not be subject to the privacy protections set forth herein.
We may collect personal information from you such as email address, phone number or mailing address when you choose to request information about our products and services, create an account, register for newsletters, request to receive customer or technical support, or otherwise communicate with us.

b. We automatically collect data about your browser or device and your use of the Site.
When you access and use the Site, our technology and tools may automatically collect and record certain data (which does not identify you as an individual) about your use of the Site (your IP address, browser type, the make and model of device used to view the Site, unique device identifiers, the referring web page, pages visited, search terms, and other information relating to your use of the Site, browser or device).
We also use various tracking technologies (such as cookies, clear GIFs, and/or pixel tags) to collect data about your use of and access to the Site. Cookies are small bits of information that may be placed on your computer by websites you visit, applications you use, or advertisements you view. Cookies alone tell us nothing about who you are. Pixel tags generate a generic notice of a visit to the Site. Pixel tags are used in conjunction with cookies to anonymously track the activity on the Site by a particular browser on a particular site.

c. Third-parties may also automatically collect data about you.
Some embedded content on the Site may be served by third-party content providers. Please note that these companies may also use cookies or other similar technologies to collect data about you, both on the Site and throughout the Internet. Data collection and use by those third-parties is subject to the privacy policies of those third-parties.

d. Our “Do Not Track” (DNT) Policy
Some websites have “do not track” features that allow you to tell a website not to track you. We do not currently respond to those signals or similar mechanism transmitted by web browsers. To learn more about browser tracking signals and DNT, please visit http://allaboutdnt.org.

e. Information from Other Sources.
We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as a SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to us, and to enhance our ability to provide you with information about our products and services.

2. Use of Collected Data
We collect and use the types of data described above to assist in the administration and operation of the Site and to provide you an efficient, meaningful, and customized experience. We may use the data to:
Fulfill our obligations with respect to the reason you volunteered the data (e.g., to respond to an inquiry, etc.);
Allow you to participate in certain features of the Site;
Improve the Site or our products, events, and services;
Optimize your experience on the Site (e.g., troubleshooting technical programs, storing your preferences, etc.);
Notify you about changes to the Site (including this Privacy Policy);
Carry out our obligations and enforce our rights arising from arrangements between you and us;
Measure interest in our products and services;
Develop new products and services;
Ensure internal quality control;
Verify Individual identity;
Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service,or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities; and
For any other purpose with your consent or as permitted by law.Additionally, we may use the data for marketing purposes to:
Provide you with additional information regarding products and services from Sfuso Inc., its affiliated companies, or from others that may be of interest to you via email, text message, or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and
Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).You can learn more about Facebook ads HERE and other types of online advertising HERE.Additionally, we may use the information for Research and Development: We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling, and other similar purposes. We may contract with third parties who provide us with other information about you, which we may then combine with the information we receive from you. We use this information to better provide our services, to customize our advertisements to you and other customers, and to provide direct marketing to you, including by e-mail and mail.From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our business and products and our business partners’ products and services or upcoming special offers/events we believe may be of interest.
Lastly, our services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services, such as “Invite a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other Third Parties for any other purpose.

Legal Basis for Processing Personal Data
To the extent you provide us with personal data, we are processing your personal data under the following lawful basis:
a. Consent: by clicking the opt-in button on the Site you consent to permit us to process your personal data for the purposes set forth in this Privacy Policy.
b. Processing necessary for compliance with legal obligations.

3. Third-Party Websites and Third-Party Embedded Content
We do not control the privacy policies of third-party websites or applications, our affiliates, service providers, and business partners which may be accessed, directly or indirectly, through your use of the Site. Any data you provide to, or that is collected by, third-parties may be subject to the privacy policies of those sites or applications (including third-party content embedded on the Site), if any. It is up to you to review the terms of use and privacy policy of third-party websites or third-party content originators.

5. Third Party Payment Processing
If you make purchases through the Site, we may process your payments through a Third-Party application. The third-party application may collect certain financial information from you to process a payment on behalf of us, including your name, email address, address and other billing information and the third-party may use such information.

6. How We Share Data
a. Affiliates and Subsidiaries. We may share your data collected on this Site with our
subsidiaries or affiliated companies.
b. Service Providers. We may provide collected data to our service providers. They may use your data to perform services for us and may have access to, store and process your personal data to provide services on our behalf.
c. Sponsors or Event Partners. In the instance of ticketed events, we may share your collected data (including personal data) with sponsors or event partners.
d. Law Enforcement and Safety. We may also share or disclose your data to comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property or safety of our users and other third-parties. We may disclose data to government or law enforcement officials or private parties as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, to comply with laws, regulations or ordinances or to prevent or stop illegal, unethical or actionable activity.
e. Business Transfer. In the event that Sfuso Inc. undergoes a merger, acquisition by another company or sale of its assets, your data will, in most instances, be part of the assets transferred.
7. Your Rights under the GDPR
If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, you have the following rights under the General Data Protection Regulation (GDPR).
Right to be informed about the collection and use of your personal data
Right to access your personal data
Right to have any inaccurate personal data corrected
Right to have your personal data erased
Right to restrict use of your personal data
Right to personal data portability
Right to object to the processing of your personal data
If you wish to exercise any of these rights under the GDPR, please contact us at the address below with such request. We will respond to any requests without undue delay and no later than one-month after receipt of your request.

8. Opting-Out of Data Use or Withdrawing Consent
As described above, we collect personal data about you when you voluntarily provide it to us and collect other data about you and your use of the Site automatically when you interact with us. If you do not want us to use your collected data as described above, or if you wish to withdraw your consent to permit us to process your personal data, please contact us at the address below with such request.
If you no longer wish to receive communications from Sfuso Inc., you can opt-out from receiving such messages in the future by following the instructions in the message or contact us below.
With respect to the Site’s use of cookies and other similar technologies, by adjusting settings on
your browser, you may elect not to allow cookies to be placed, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data about you.
You may remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt- Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools). Please note that these opt-out tools are device and browser specific, so you must repeat the opt-out from each of your browsers and devices.
You may also adjust your advertising preferences on various social media websites by adjusting your settings on the platform (for example, you may adjust the types of Facebook ads you receive HERE).

9. Protection and Retention of Data
We use appropriate technical and organizational measures to ensure a level of security appropriate to the risk and to safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risks in connection with data sent to us or collected by us.
We retain data only as long as necessary in light of the reasons it was collected as set forth in this Privacy Policy, or until you inform us you wish to have your data deleted, whichever comes first. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

10. 21 Years of Age or Older
Due to the Company’s goods and services we do not target or knowingly or intentionally collect personally identifiable information from anyone under the age of 21. By using the Site, you have represented and warranted that you are 21 years of age or older. If you are under the age of 21, you may not use the Site.

11. Mobile Devices
We may occasionally send you push notifications through our mobile applications, with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location- based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

12. Data Controller
The data controller for the personal data that you provide or that is collected by Sfuso Inc. is Sfuso Inc., 89 Winslow St, Everett, MA 02149.

13. Miscellaneous
From time to time, we may update this Privacy Policy to reflect, among other things, changes in the law or our data collection and use practices and such modifications shall be effective upon posting by Sfuso Inc.. Your continued use of the Site after an updated Privacy Policy signifies your acceptance of the revised Privacy Policy. It is important that you review this Privacy Policy regularly to ensure you are updated as to any changes. If we make a material change to this Privacy Policy, as determined in our sole discretion, we will notify you via email.

15. Contact Us
If you have any general questions about this Privacy Policy or other aspects of the Site or would like to correct, update or erase data provided to us, please email us at privacy@sfuso.app