Effective as of October 17, 2018
Table of Contents:
1. Scope and Application, what and who this Policy covers.
2. Collection of Information, the sources of and methods by which we, our service providers and our advertisers collect information from and about you, including information about your interaction with the Today Posts Services
3. Use and Disclosure. How we use the information we collect from and about you, and who we might share it with and why.
4. Security. How we protect your information from loss or misuse
5. User Access and Control. How you can access and control the information we maintain about you
6. Other Important Information. Other things you should know about this Policy and how we handle your information
7. Contact Us. How to contact Today Posts about this Policy
PLEASE READ THIS PRIVACY POLICY AND THE RELATED TERMS OF USE LOCATED AT www.Today Posts.com/terms-of-use CAREFULLY BEFORE USING THE TODAY POSTS SERVICES.
1) Scope and Application
Today Posts Network, LLC (“Today Posts” or “we” or “our”) wants you to be familiar with how we collect, use and disclose information from and about you. This Privacy Policy describes our practices in connection with information collected, used or shared through services such as websites, mobile sites, applications (“apps”), and widgets (collectively, the “Today Posts Services”) (unless a different policy is provided on a particular website or app, in which case such different policy shall control data collected through that particular website or app). By using Today Posts Services, you agree to the terms and conditions of this Privacy Policy. A list of our affiliated companies (“Company Affiliates”) is available at www.21cf.com.
As set forth in our Terms of Use, the Today Posts Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 13 years of age.
This Privacy Policy applies to all users, including both those who use the Today Posts Services without being registered with [or subscribing to] a Today Posts Service and those who have registered with [or subscribed to] a Today Posts Service. This Privacy Policy applies to our collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address). It also describes generally our practices for handling non-personal information (for example, interests, demographics and services usage).
By providing personal information to us and/or using the Today Posts Services, you unconditionally consent and agree to the terms and conditions of this Privacy Policy. If you do not consent to the collection and use of information from or about you in accordance with this Privacy Policy, then you may not use the Today Posts Services.
2) Collection of Information
Today Posts and our service providers collect the following information from and about you:
Registration Information is the information you submit to register for a Today Posts Service, for example, to create an account, post comments, receive a newsletter, or enter a contest or sweepstakes. Registration Information may include, for example, name, email address, gender, zip code and birthday. Today Posts may allow for multiple profiles to be set up under one account. If this occurs, we may collect information you provide to us if you create a profile.
Other Voluntarily Provided Information. Today Posts may collect information you provide to us when you respond to surveys, set your preferences, contact Today Posts through customer service or by other means, or participate in promotions that Today Posts may offer from time to time. Today Posts also may collect information you provide to use when you place an order on a Today Posts Service. This information is used to provide the products and services that you have ordered or requested, to process and ship orders, to send order and shipping confirmations and to provide customer service. This information also may be used to contact you about sales, special offers and new website features, unless you have opted not to receive promotional communications in connection with this Today Posts Services. We may also ask you to provide us with demographic information, information regarding your interests or similar information. Providing us with information about yourself is voluntary, and you can always choose not to provide certain information, but then you may not be able to take advantage of or participate in some of the Today Posts Services’ features.
Public Information and Posts consist of comments or content that you post to the Today Posts Services and the information about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
Information from Social Media. If you access or log-in to a Today Posts Service through a social media service or connect a Today Posts Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Today Posts Services through social media services or when you connect a Today Posts Service to social media services, you are authorizing Today Posts to collect, store, and use such information and content in accordance with this Privacy Policy.
Activity Information. When you access and interact with the Today Posts Services, Today Posts and its service providers may collect certain information about those visits. For example, in order to permit your connection to the Today Posts Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access the Today Posts Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data (including your precise location), or other transactional information for that device.
Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. These technologies are discussed below.
Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) are comprised of small bits of data. Today Posts’ websites, apps and other services send this data to your browser when you first request a web page and then store the data on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also be used to collect and store information about your usage of the Today Posts Services, such as pages you have visited, the video and other content you have viewed, search queries you have run and advertisements you have seen.
Third parties that support the Today Posts Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate Today Posts Services usage statistics, may also use these technologies to collect similar information when you use the Today Posts Services (such as websites and emails) or third-party services. These third parties may also use these technologies, along with Activity Information they collect, to recognize you across the devices you use, such as a mobile device and a laptop or other computer. Today Posts does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled “To deliver relevant advertisements,” below.
Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Please note that by blocking any or all cookies you may not have access to certain features, content or personalization available through the Today Posts Services.
Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services, commercially available sources and information from our Company Affiliates or business partners. Examples of this may include information (whether identified, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behavior, and your activities online (such as websites visited and advertisements viewed.
Do Not Track Signals. At this time we do not respond to browser ‘Do Not Track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.
3) Use and Disclosure
To provide and manage the Today Posts Services. We use the information we collect from and about you to provide the Today Posts Services and features to you, including: to measure and improve those Today Posts Services and features and to develop new products and services; to improve your experience with both online and off-line Today Posts Services by delivering content you will find relevant and interesting, including advertising and marketing messages; to allow you to comment on content, and participate in online games, contests, other promotions, or rewards programs; to provide you with customer support and to respond to inquiries. In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
To allow service providers to assist us in providing and managing the Today Posts Services. The information we collect from and about you may be made available to certain third party service providers, such as contractors, analytics and other measurement companies, product customization companies, order fulfillment and shipping companies, agents or sponsors, who help us analyze and understand your use of the Today Posts Services, and manage and/or provide the Today Posts Services.
To allow social sharing functionality. If you log in with or connect a social media service account with Today Posts Services, we may share your user name, picture, and likes, as well as your activities and comments with other Today Posts Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Today Posts Services account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with your Today Posts Services account and do not participate in social sharing on Today Posts Services.
To provide co-branded services and features. We may offer co-branded services or features, such as contests, sweepstakes or other promotions together with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted on Today Posts Services or on the third party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy policy.
To deliver relevant advertisements. Today Posts and our service providers may use the information we collect from and about you as described in this Privacy Policy to deliver relevant ads to you when you use the Today Posts Services or another service (on any of your devices). As noted above, third-party advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and information about the different devices you use and your activity on such devices, to assist them in delivering advertising that is more relevant to your interests. The information may also be used to deliver more relevant advertising to you across marketing channels, including email. To find out more about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info. If you would like to opt-out of such ad networks’ and services’ advertising practices on the particular device on which you are accessing this policy, go to http://optout.aboutads.info/ to opt-out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt-out in mobile apps.
To contact you. Today Posts may periodically send promotional materials or notifications related to the Today Posts Services. If you want to stop receiving promotional materials, you can change your account setting [describe applicable way to opt-out] or follow the unsubscribe instructions at the bottom of each email. There are certain service notification or other non-promotional emails that you may not opt-out of, such as notifications of changes to the Today Posts Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
To share with our Company Affiliates. Today Posts may share your information with Today Posts Affiliates for the purposes described in this Privacy Policy. A link to a website that lists Today Posts Affiliates can be found at the beginning of this policy. Users who visit Today Posts Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy.
To share with business partners. Today Posts may share your information with business partners to permit them to send you marketing communications consistent with your choices.
To protect the rights of Today Posts and others. There may be instances when Today Posts may use or disclose your information, including situations where Today Posts has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Today Posts, our Company Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of the Today Posts Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.
To complete a merger or sale of assets. If Today Posts sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), Today Posts may transfer your information to the party or parties involved in the transaction as part of that transaction.
Other Uses. We may also use the information we collect for any other uses in accordance with our Terms of Use and any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.
Use of Aggregate or De-Identified Information. In addition to the individual data uses described in this Privacy Policy, we may aggregate information about you and/or other individuals together, or otherwise “de-identify” the information about you (which means that the information does not identify you personally). We may also use de-identified information for any legitimate business purpose, including for research and analysis, administration of the Today Posts Services, advertising (e.g., improving our targeting efforts, if applicable) and promotional purposes.
4) Security
Today Posts uses commercially reasonable administrative, technical, personnel and physical measures designed to safeguard information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information. If you place an order through this Today Posts Services, you will be asked to set up an account and provide an email address and password. You must provide an appropriate email address and password in order to access account information. In order to help protect your personal information further, you should be careful about providing your password to others. If you wish to cancel a password, or if you become aware of any loss, theft or unauthorized use of a password, please contact our customer service department via Today Posts.com/contactus
5) User Access and Control
If you would like to access, review, correct, update, suppress, delete, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us as outlined in Section 7; or using the mechanisms provided below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, suppress, or delete. We will try to comply with your request as soon as reasonably practicable.
We give you many choices regarding our use and disclosure of your personal information for marketing purposes. We will try to comply with your request(s) as soon as reasonably practicable. You may opt-out from:
Opt-Out of Promotional Communications: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in the email. Please note that you cannot opt out from receiving all communications from Today Posts, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information.
Push Notifications: You can choose to receive push notifications from Today Posts on your device. If you do not wish to receive push notifications, you can use your device’s settings to turn them off.
Our sharing of your personal information with Company Affiliates for their marketing purposes: If you would prefer that we do not share your personal information on a going-forward basis with Today Posts Affiliates for their direct marketing purposes, you may opt-out of this sharing via: Today Posts.com/contactus. We will try to comply with your request(s) as soon as reasonably practicable.
Our sharing of your personal information with business partners for their marketing purposes: If you would prefer that we do not share your personal information on a going-forward basis with business partners for their direct marketing purposes, you may opt-out of this sharing via: Today Posts.com/contactus. We will try to comply with your request(s) as soon as reasonably practicable.
Cancelling your account. To cancel your account, go to TodayPosts.com and click “cancel account”. Remember that even after you cancel your account, copies of some information from your account may remain viewable in some circumstances – where, for example, you have shared information with a third-party application or web site. We may also retain backup information related to your account on our servers for some time after cancelation for fraud detection or to comply with applicable law or our internal security policies. Because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.
Additional Choices for California Residents
If you are a California resident, you may be entitled to request certain information regarding our disclosure, if any, of personal information (such as your name and contact information) to third parties who wish to contact you or send you promotional information about their products and services directly (as compared to when the third party is acting on our behalf or you have provided your personal information as part of a co-promotion by Today Posts and the third party). If you are a California resident and would like to request a copy of information regarding our disclosure to third parties for their direct marketing purposes in the preceding calendar year, please send us a letter at Today Posts, 1211 Avenue of the Americas, New York NY 10036, Attn: Legal Department.
If you are a California resident under the age of 18 and a registered user of the Today Posts Services, you may request and obtain removal of content or information you have publicly posted on the Today Posts Services. To make this request, please contact us via TodayPosts.com/contactus and include a detailed description of the specific content or information you would like to remove. Please note that this removal does not ensure complete or comprehensive removal of the content or information posted on the Today Posts Services by you as there may be circumstances in which the law does not require or allow removal.
6) Other Important Information
Updates to Privacy Policy. Today Posts may modify this Privacy Policy to reflect changes in the law or the Today Posts Services or for other reasons. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Today Posts Services.
Location of Data. The Today Posts Services are hosted in and managed from the United States. If you are a user located outside the United States, you understand and consent to having any personal information (which may include information collected through the use of cookies and other technologies, as described above) processed in the United States or in any other country in which we have facilities or in which we engage service providers. United States and other countries’ data protection laws may not be the same as those in your jurisdiction. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in the United States may be entitled to access your personal information.
Linked Services. The Today Posts Services may be linked to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. Today Posts is not responsible for the privacy practices of unaffiliated companies, and once you leave the Today Posts Services or click an advertisement you should check the applicable privacy policy of the other service.
In addition, Today Posts is not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Today Posts Services.
Collection of Personal Financial Information by a Payment Service. In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.
Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.
Remember that even after you cancel your account, or if you ask us to delete your personal information, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, for fraud detection or to comply with applicable law or our internal security or recordkeeping policies. It may not always be possible to completely remove or delete all of your information due to technical constraints, or contractual, financial or legal requirements.
Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such as social security numbers, information related to racial or ethnic origin, religion or other beliefs, health, criminal background or trade union membership) on or through the Today Posts Services or otherwise. Your use of the Today Posts Services is at your own risk. Today Posts urges you to take steps to keep your information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your account, and closing your web browser. In order to help us protect your sensitive further, you should be careful about providing your password to others.
Whenever you give Today Posts sensitive or confidential information, Today Posts will take commercially reasonable steps to protect the information by establishing a secure connection with your web browser. Today Posts uses an industry standard security protocol for encrypting sensitive information. Unfortunately, no security measures are perfect or impenetrable and data transmission over the Internet cannot be guaranteed 100% secure. We cannot and do not ensure or warrant the security of any information you transmit to Today Posts and you do so at your own risk.
7) Contact Us
If you have questions about this Privacy Policy, please contact us at:
Email: Hello@TodayPosts.com
