Effective Date: December 6, 2022
We at CB Neptune Holdings, L.L.C. and CB Neptune Promotions Inc. (collectively, "Neptune " or "we"), respect your concerns about privacy. This Privacy Notice ("Notice") applies to personal consumer information obtained by Neptune, including through (1) www.checkout51.com and www.checkout51.ca, (2) the Checkout 51 mobile app, (3) marketing experiences accessed via scannable quick response (QR) codes, near field communications or other methods, which may or may not relate to the brands, websites and/or apps listed above, (4) surveys, product sampling and other offer distribution opportunities and (5) emails related to the above ((1) through (5), collectively, the "Services").
The Notice describes the types of personal information we obtain about consumers, how we use the information and with whom we share it. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. The Services are for a general audience, are not targeted to children, and we do not knowingly collect personal information from children under 16 years of age.
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Information Obtained by Automated Means Through Our Services
Accessing, Reviewing, Updating and Modifying Personal Information
Information We Obtain
We obtain personal information about consumers through the Services, publicly and commercially available sources and from our Neptune affiliates and/or business partners (such as consumer product companies, retailers, social media networks, etc.). The types of personal information we may obtain include:
Contact information (such as name, postal address, email address and telephone and/or mobile numbers);
Username and password when you register through our Services;
Other registration information such as store loyalty card numbers you elect to register;
Geolocation data which may include city, state and zip code associated with your IP address, information derived through Wi-Fi triangulation, and, with your permission in accordance with your mobile device settings, precise geo-location information from GPS-based functionality on your mobile devices;
Information on receipts made available to us through the Services, such as the items and date(s) of your purchases, prices of the items, methods of payment, the last four digits of your credit card number, signature, and names and locations of the merchants ("Receipt Data");
Purchase transaction data and other data provided by our business partners that we match to you through information you have provided to us, such as store loyalty card numbers, contact information or other identifying information;
Contact information for friends or other people you would like us to contact
Other information you may provide to us, such as through our "Submit a Request" feature.
Information Obtained by Automated Means Through Our Services
A "cookie" is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A "web beacon" also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain "clickstream data," which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We also may use similar automated means to obtain and store information regarding your actions while using our mobile apps.
We may link certain data elements obtained through automated means, such as your browser or device information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you, what search queries you may have run and what advertisements you may have seen on our Services or on third-party websites and apps. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Services, and location services must be enabled through your mobile operating system for certain location-based elements of the Services to operate. Your device settings also may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with app developers of apps such as Checkout 51.
In addition, if you register for the Services through or connect your Checkout 51 account to a third-party social media network or service (such as Google, Facebook or Twitter), we may obtain certain information about you from the relevant social media network or service, such as your user ID and/or user name associated with that social media network or service, the information contained in your public profile on the social media network and friends lists. The specific information we obtain depends on your privacy settings on the applicable social media network or service.
The providers of third-party apps, tools, widgets, plug-ins and application programming interfaces (APIs) on our Services, such as social media sharing tools and location-based services, also may use automated means to collect information regarding your interactions with or use of these features. This information may be collected directly by the providers of those features or shared by us with such providers and is subject to the privacy policies or notices of those providers. Neptune is not responsible for those providers’ information practices.
How We Use the Information We Obtain
We may use the information collected from and about you to:
Provide our products and services, such as coupon delivery services and offers based on your location;
Create and manage online accounts;
Send promotional materials, alerts regarding available offers and other communications, including communications through the Services and outside of the Services, such as via mail, email and through third-party websites and apps;
Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;
Anonymize personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;
Supplement your personal information collected from you with additional information from publicly and commercially available sources, and/or information from Neptune affiliates and our business partners;
Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content, advertising across browsers and devices, and other operational/business purposes;
Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities, including to protect against offer stacking and enforce other offer restrictions; and
Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.
We may use third-party analytics services on our Services, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons, web server logs and similar technologies to help us analyze your use of the Services. The information collected through these means may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the Services. To learn more about how to opt out of Google Analytics services, please visit the link below:
Google Analytics: https://tools.google.com/dlpage/gaoptout
We also may use your personal information in other ways for which we provide specific notice at the time of collection.
Through our Services, we and our third-party service providers may obtain information about your activities to provide you with advertising about products and services tailored to your individual interests. We and our third-party service providers also may obtain information for this purpose from third-party websites and apps. This section of our Privacy Notice provides details and explains how to exercise your choices.
We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means. Through these ad networks , we can track your online activities over time and across third-party websites and apps by obtaining information through automated means, as described above. The networks use this information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests. The information our ad networks may obtain on our behalf includes data about your visits to websites and use of apps that serve Neptune advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our sites, apps and emails and on third-party websites and apps that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising,
To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our sites are not designed to respond to "do not track" signals from browsers.
If you so elect, you may provide your mobile phone number to Neptune. By submitting your mobile phone number, you consent to receive text message alerts from Neptune containing promotions, offers, contest and event information, or product information that may be sent using automated dialing systems ("Text Messages"). Your consent to receive Text Messages is not otherwise required to purchase or receive any goods or services from us. You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number. You agree to enter into, sign and receive your consent to receive Text Messages electronically. You can contact us as set forth under "How to Contact Us" below to request a free copy of your consent.
You may receive recurring Text Messages. We do not charge a fee for you to receive Text Messages from us; however, your mobile service provider may charge you for sending and/or receiving Text Messages and air-time, as well as any other standard applicable rates charged by your mobile service provider.
Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery or guarantee availability or performance of this service, including liability for transmission delays or message failures. To receive help with Text Messages, you can contact us as set forth under the How to Contact Us Section below.
You may unsubscribe from receiving Neptune Text Messages any time by texting the word "STOP" to the short code listed here from your device. You may also choose not to receive Text Messages by contacting us as set forth under the How to Contact Us Section below and specifying that this is your preference.
We may also obtain the date, time and content of your messages in the course of your use of Text Messages. We will use the information we obtain in connection with our Text Messages in accordance with this Privacy Notice.
From time to time you may be asked to provide your mobile phone number to Neptune in connection with specific text messaging programs. Some text messaging programs may have additional or different terms and conditions from those set forth above, which will be presented to you at the time that you opt-in to receive those Text Messages.
In general, in order to stop receiving Text Messages from a specific Neptune text messaging program, you can text STOP to the short code for the text messaging program from which you no longer wish to receive message (i.e., the number from which its Text Messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. This will only opt you out of the specific text messaging program associated with that short code. You will remain opted in to any other Neptune text messaging programs that you have signed up for.
Push Notifications and In-App Alerts and Updates
When you download one of our mobile applications, we may provide you with the option to opt in to receive push notifications from Neptune on your mobile device in connection with that mobile application. These push notifications may include promotional communications regarding Neptune products and services. You may, after downloading the applicable mobile application, opt out of receiving push notifications by adjusting the settings on your mobile device. Opting out of push notifications will not affect other communications you receive from Neptune, such as email communications. You also may receive alerts and updates within our mobile applications regarding Neptune products and services or your Neptune accounts. To opt out of receiving these alerts and updates, you may uninstall the applicable mobile application from your mobile device.
We may share consumer personal information with
Our subsidiaries and affiliates, any of whom may use your personal information consistent with this Privacy Notice or for the subsidiary’s or affiliate’s own purposes, including marketing purposes.
Service providers in the US and other jurisdictions who perform services on our behalf.
Our third party clients or business partners, such as consumer product companies and other third parties for those third parties’ own marketing purposes, such as to serve targeted advertisements.
From time to time, using encryption technology, we may compare our consumer member databases with our affiliates’, clients’ and/or partners’ databases to identify overlap between the databases. When there is an overlap between databases, we may share with those affiliates, clients and/or partners information such as Receipt Data and other data in our possession, including data collected via automated means, as described above, of the matched consumers. Those parties may use this information as permitted under their own privacy notices, including to contact consumers and/or to send targeted advertising or other promotional materials.
In addition, when the information collected from or about you does not identify you as a specific person, we may share it with third parties.
In addition, we may disclose information about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, and (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).
We offer you certain choices in connection with the personal information we obtain about you, such as how we communicate with you.
To update your preferences, ask us to remove your information from our marketing emailing lists (such as Checkout51’s weekly reminder email) or submit a request, please contact us as outlined in the How to Contact Us Section below. Additionally, all users can change their notification preferences and Canadian users can change their email and data sharing preferences in the Settings section of the Checkout 51 mobile app.
You also can unsubscribe from our marketing emailing lists by following the "Unsubscribe" link in our emails.
In general, in order to stop receiving text messages, you can text STOP to the short code for the text messaging program from which you no longer wish to receive message (i.e., the number from which the text messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. Please note that this will only opt you out of the specific text messaging program associated with that short code. You will remain opted in to any other Neptune text messaging programs that you may have signed up for. To unsubscribe from the Neptune general marketing text messaging program you can text "STOP" to the short code listed here from your device.
You may also choose not to receive text messages by contacting us as outlined in the How to Contact Us Section below and specifying that you no longer want to receive Text Messages.
To turn on or off location-based services, you can adjust the settings within your mobile operating system (e.g., currently for iOS, you can go to Settings â†’ Privacy â†’ Location Services â†’ Checkout 51).
Accessing, Reviewing, Updating and Modifying Personal Information
You have the right to access, review, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in your personal information by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
To learn more about how to opt out of ad network interest-based advertising, please visit the consumer opt-out pages at:
In the US: http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/.
In Canada: https://youradchoices.ca/.
Deleting Your Account
If you have signed up for Checkout 51, you may decide you want to delete your Checkout 51 account and the data associated with it. When you delete your account we delete your name, email, home address, birthday, gender and household information. Any Cash Back rewards accumulated in your account will be forfeited when you delete.
After deleting your account, youâ€™ll be unable to log in to Checkout 51. It can take up to 24 hours for us to finish deleting your account, we will send an email when itâ€™s complete. Please note that deleting your account cannot be undone. You can come back any time by signing up for a new account using any of our sign in options.
To delete your account, you can complete this process within your Checkout 51 App (e.g., currently for iOS, you can go to Profile → Settings & Preferences → Delete Account)
If you have not signed up for Checkout 51, we donâ€™t keep a record of your account and there is not an option to delete (e.g. for iOS Apps, you can see and interact with offers prior to signing up).
Data Retention Policy
We store your information to fulfil contractual obligations as well as to comply with local laws and regulations. If at any time youâ€™d like to remove your information, see Deleting Your Account.
Notice To California Residents â€“ California Privacy Rights
Solely for purposes of this portion of the Notice for California Residents, references to "we" and "us" shall be deemed references to Checkout 51 and references to "Services" shall be deemed references to services provided by Checkout 51, including through (1) www.checkout51.com, (2) the Checkout 51 mobile app, (3) marketing experiences accessed via scannable quick response (QR) codes, near field communications or other methods, which may or may not relate to Checkout 51, (4) surveys, product sampling and other offer distribution opportunities and (5) emails related to the above.
NOTICE TO CALIFORNIA RESIDENTS â€“ CALIFORNIA SHINE THE LIGHT LAW
Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us as specified in the How to Contact Us section of the Notice https://staging.checkout51.com/privacy#your-california-privacy-rights.
For all such requests, please indicate "California Shine the Light" in the subject field of your request and include the name of the Checkout 51 Service with respect to which you are requesting the information. You must also include your full name and email address.
NOTICE TO CALIFORNIA RESIDENTS - CALIFORNIA CONSUMER PRIVACY PROTECTION ACT
The California Consumer Privacy Act of 2018 ("CCPA") provides certain rights to residents of California. This section of the Notice applies if you are a natural person who is a resident of California ("California Consumer") and use our Services. This notice supplements the information in the Notice (https://staging.checkout51.com/privacy#your-california-privacy-rights). Certain terms used below have the meanings given to them in the CCPA.
The following sets forth the categories of information we collect and purposes for which we may use California Consumersâ€™ personal information:
CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU, WHY AND HOW
Summarized in the table below are the categories of personal information we may have collected about you over the past twelve (12) months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.
|Categories of information collected||Purposes of collection||Sources of personal information|
More details on the categories of personal information, the purposes for which we collected such information and the sources from which we obtain your personal information are outlined below, and otherwise set forth in the Information We Obtain and How We Use the Information We Obtain sections of our Notice.
CATEGORIES OF PERSONAL INFORMATION COLLECTED
Identifiers which may include your contact information (such as name, email address, telephone and/or mobile number, postal address) or unique personal identifiers (such as device ID, cookies, IP address, mobile device advertising identifier and similar technology, Facebook ID, retailer loyalty card number) ("Identifiers");
Commercial information which may include transaction data, purchase history, or delivery information ("Commercial Data");
Internet or other network or device activity which may include browsing history, search history, app usage, browser characteristics, device characteristics, operating system, language preferences ("Internet Data");
Geo-location information which may include city, state and zip code associated with your IP address, information derived through Wi-Fi triangulation, and, with your permission in accordance with your mobile device settings, precise geo-location information from GPS-based functionality on your mobile devices ("Geo-location Data");
Inference information about you which may include preferences, characteristics, and behaviors ("Inference Data");
Legally protected classifications which may include gender ("Protected Data");
Profile data about you and any inferences drawn from the profile data which may include characteristics, behaviors, attitudes ("Profile Data");
Information that identifies or can be reasonably associated with you ("Associated Data").
BUSINESS OR COMMERCIAL PURPOSES FOR WHICH WE COLLECTED OR DISCLOSED PERSONAL INFORMATION
performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services ("Performing Services");
auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance ("Auditing");
short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction ("Short-term Use");
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity ("Data Security and Fraud Prevention");
debugging to identify and repair errors that impair existing intended functionality ("Repairs");
undertaking internal research for technological development and demonstration ("Research and Development");
undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by us, and to improve, upgrade, or enhance the service that is owned or controlled by us ("Quality and Safety"); and
to advance the commercial or economic interests of Checkout 51, such as by inducing another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction ("Commercial Interests").
CATEGORIES OF SOURCES FROM WHICH WE COLLECTED PERSONAL INFORMATION
Directly from you ("You");
From other sources (such as Company affiliates and/or business partners; advertising providers; analytics providers; marketers; consumer data resellers; social media networks, in accordance with your privacy preferences on such services; researchers; and surveys)("Affiliates and Partners");
Through your use of the Services ("Services Use").
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
We will share the personal information collected from and about you over the past twelve (12) months as discussed above for various business purposes. The chart below explains the categories of information that we may share with third parties and the categories of those parties.
|Third Parties with which we share information and why||Categories of information shared|
Our Subsidiaries and Affiliated Businesses. We may share information we collect within our family of companies to deliver products and services to you, and enhance our products, services, and your customer experience, consistent with our Notice. Those businesses may also use your information for their own purposes, including marketing purposes.
Third Party Partners for Marketing Purposes. We may share your information with partners whose offerings we think may interest you. For example, if you redeem Checkout 51 Offers, then we may share information with third parties for their marketing and other purposes.
Third Parties for Legal Requirements and Proceedings. We may disclose information to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other law enforcement or government measures, and to comply with other legal obligations. We may disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.
Third Parties for the Protection of our Services and Users. We may disclose information to protect and defend the rights, interests, and safety of the Services, our subsidiaries and affiliates, and their employees, contractors and agents; to protect the security and safety of our users of the Services, including when we believe disclosure is necessary to prevent physical harm or financial loss.
Third Parties in Business Transfers. We may disclose information in connection with a proposed or completed corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets.
Third-Party Online Advertisers and Ad Networks. As discussed in the Interest-Based Advertising section of our Privacy Notice, the Services may rely on third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Services to assist in delivering such ads.
Data Analytics Providers. We may share information with companies that provide data analytics services in order to operate, evaluate and improve our business.
Social Networks. As discussed in the Information We Share section of our Notice, we may share your information with social networking services for their commercial or marketing purposes.
Consumer Data Resellers. We may share information with consumer data resellers for marketing or commercial purposes.
CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES
California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:
The right to access and disclosure. You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you during the past 12 months:
the categories and specific pieces of personal information we have collected about you;
the categories of sources from which we collected the personal information;
the business or commercial purpose for which we collected or sold the personal information;
the categories of third parties with whom we shared the personal information; and
the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.
The right to deletion. You may have the right to request that we delete the personal information we have collected from you.
Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.
How to exercise your access and deletion rights.
California residents may exercise their California privacy rights by submitting a request through https://www.checkout51.com/ccpa or by leaving a voice message including your name, email address, phone number and request at this toll free number: 1-888-222-8703
For security purposes, we will verify your identity â€“ in part by requesting certain information from you -- when you request to exercise your California privacy rights. For instance, you will need to provide: your full name and email address or such other information as is necessary to verify your identity. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, you will need to provide: your full name and email address or such other information as is necessary to verify your identity or authenticate your request.
Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:
Where you have requested the categories of personal information that we have collected about you, we will provide such information in a reasonably secure method.
Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.
Where you have requested that we delete personal information that we have collected from you, we will delete, deidentify, and/or aggregate any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.
If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.
The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
The right to opt-out of the sale of your personal information. You have the right to opt out of the sale of your personal information. California law broadly defines sale such that it may include, for example, allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior.
If you would like to opt out, you may do so as outlined on the following page: Do Not Sell My Personal Information
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
HOW TO CONTACT US
If you are a California Consumer, to submit a request, please contact us at https://www.checkout51.com/ccpa or at firstname.lastname@example.org. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal information we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Transfers of Information
Links to Third-Party Sites, Apps and Services
For your convenience and information, our Services may provide links to third-party sites, apps and services that may be operated by companies not affiliated with Neptune. These companies may have their own privacy notices or policies, which we strongly suggest you review. We are not responsible for the privacy practices of any non-Neptune sites, apps or services.
Updates to Our Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. For significant changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Notice when it was most recently updated.
How To Contact Us
If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal information, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us as follows:
Checkout 51: support request
You also may write to:
Neptune Retail Solutions
545 Washington Blvd.,
Jersey City, New Jersey, 07310
Canadian residents may also contact our Privacy Officer by email at email@example.com.