Privacy Policy
This Messaging Program Privacy Policy explains how West Ave Holdings LLC collects and uses information about you in relation to its text message marketing program (the “Messaging Service”). We use a third-party service called Launch Control to provide the Messaging Service to you. For the purposes of the Messaging Service, Launch Control acts as our service provider and data processor of your information.
Collection of Information
We collect various information on our behalf from and about you, including information you directly provide when you use the Messaging Service. For example, we collect the phone number and email address you provided when signing up for the Messaging Service. When you send messages via the Messaging Service, we will also collect your messaging history and any information included in those messages.
We may also collect information about you using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable personalization of your experience on the Messaging Service (e.g., sending you personalized text messages such as shopping cart reminders).
If you participate in a contest, sweepstakes, research study, or email survey associated with the Messaging Service, we will collect basic contact information and any other information you choose to provide in connection with these activities. We will also collect your contact information if you contact us with questions about the Messaging Service or for customer service.
Use of Information
We use your information to deliver, analyze, maintain, and support the Messaging Service. We may also use your information to enhance the Messaging Service features and customize and personalize your experiences on the Messaging Service.
Sharing of Information
We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:
Service Providers. We may share your information with third parties to help us provide the Messaging Service to you.
Legal Requirement and Protection of West Ave Holdings LLC and Others We may disclose your information as we believe such disclosure is necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce a contract with us; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.
From time to time, we may share aggregate or de-identified information about the use of the Messaging Service and such aggregated or de-identified information may be shared with any third party, including advertisers, promotional partners, and sponsors.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties.
Protection of Information
We take a variety of physical, technical, administrative, and organizational security measures based on the sensitivity of the information we collect to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. Unfortunately, no online activity can be guaranteed to be 100% secure. While we strive to protect your information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide. We do not accept liability for unintentional disclosure.
Retention of Information
We retain your information for as long as you participate in the Messaging Service or as needed to comply with applicable legal obligations. We will also retain and use your information as necessary to resolve disputes, protect us and our customers, and enforce our agreements.
Choices and Controls
Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving further commercial text messages via the Messaging Service by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT.
Text Message Campaign Data Selling
If you sign up to receive text messages from us, we will not sell Personal Information collected specifically in connection with such service, including your mobile telephone number or consent data, to any third party, and we will not share such Personal Information with any third party for cross-context behavioral advertising or targeted advertising purposes.
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Privacy Policy
Last Updated:
We value your privacy very highly. Please read this Privacy Policy carefully before using the Website (the "Website") operated by , a(n) formed or residing in , ("us," "we," "our") as this Privacy Policy contains important information regarding your privacy and how we may use the information we collect about you.
Your access to and use of the Website is conditional upon your acceptance of and compliance with this Privacy Policy. This Privacy Policy applies to everyone, including, but not limited to: visitors, users, and others, who wish to access or use the Website.
By accessing or using the Website, you agree to be bound by this Privacy Policy. If you disagree with any part of the Privacy Policy, then you do not have our permission to access or use the Website.
What information we collect, where we get this information, how we use this information, what happens if we don't have it, and the legal basis for processing this information
We collect and store any and all information that you enter on this Website. We collect and store the following information about you:
Identifying information - Name
Specific piece of information
Name
Legal basis for processing this information.
The user has provided consent to the processing of their information;
Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
Processing is necessary for compliance with a legal obligation.
Where we get this information
Information submitted by the consumer;
The observation and recording of activities by the business, such as through the use of cookies.
How we use this information
Analytics;
Performing services;
Providing customer service;
Verifying customer information.
What happens if we don't have this information
Our use of your data for analytics will not be possible;
Our use of your data for performing services will not be possible;
Our use of your data for providing customer service will not be possible;
Our use of your data for verifying customer information will not be possible.
Identifying information - Billing address
Specific piece of information
Phone number
Legal basis for processing this information
The user has provided consent to the processing of their information;
Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
Processing is necessary for compliance with a legal obligation.
Where we get this information
Information submitted by the consumer;
The observation and recording of activities by the business, such as through the use of cookies.
How we use this information
Analytics;Performing services;
Providing customer service;
Verifying customer information.
What happens if we don't have this information
Our use of your data for analytics will not be possible;
Our use of your data for performing services will not be possible;
Our use of your data for providing customer service will not be possible;
Our use of your data for verifying customer information will not be possible.
Identifying information - IP address
Specific piece of information
IP address
Legal basis for processing this information
The user has provided consent to the processing of their information;
Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
Processing is necessary for compliance with a legal obligation.
Where we get this information
Information submitted by the consumer;
The observation and recording of activities by the business, such as through the use of cookies.
How we use this information
Analytics;
Performing services;
Providing customer service;
Verifying customer information.
What happens if we don't have this information
Our use of your data for analytics will not be possible;
Our use of your data for performing services will not be possible;
Our use of your data for providing customer service will not be possible;
Our use of your data for verifying customer information will not be possible.
Identifying information - Email address
Specific piece of information
Email Address
Legal basis for processing this information.
The user has provided consent to the processing of their information;
Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
Processing is necessary for compliance with a legal obligation.
Where we get this information
Information submitted by the consumer;
The observation and recording of activities by the business, such as through the use of cookies.
How we use this information
Analytics;
Performing services;
Providing customer service;
Verifying customer information.
What happens if we don't have this information
Our use of your data for analytics will not be possible;
Our use of your data for performing services will not be possible;
Our use of your data for providing customer service will not be possible;
Our use of your data for verifying customer information will not be possible.
Identifying information - Device identifier
Specific piece of information
Device identifier
Legal basis for processing this information.
The user has provided consent to the processing of their information;
Processing is necessary in order to take steps that the user has requested prior to entering into a contract;
Processing is necessary for compliance with a legal obligation.
Where we get this information
Information submitted by the consumer;
The observation and recording of activities by the business, such as through the use of cookies.
How we use this information
Analytics;
Performing services;
Providing customer service;
Verifying customer information.
What happens if we don't have this information
Our use of your data for analytics will not be possible;
Our use of your data for performing services will not be possible;
Our use of your data for providing customer service will not be possible;
Our use of your data for verifying customer information will not be possible.
We are not required to collect this information by a law, court order, nor by a tribunal order. We do not combine nor link the personal information that we hold about you.
Note that we may use your personal information for the purpose of automated decision making. Please see the "Your Rights" section below for more information regarding exercising your privacy rights related to automated decision making.
With whom we share your personal information
We do not share your personal information with any third parties.
How we protect your personal information
We have implemented the following measures to protect and safeguard your personal information:
Limiting the amount of personal information that we collect to strictly necessary only;
Using ssl or other secure connection technologies when receiving or sending personal information beyond internal networks;
Destroying the personal information that we no longer need;
Performing regular risk assessments;
Having comprehensive security policies and procedures;
Training our employees;
Implementing and monitoring intrusion prevention and detection systems;
Maintaining up-to-date software and safeguards;
Implementing physical security measures.
Sale of your information
We do not sell your personal information.
Cookies
A cookie is a small piece of data sent from a website and stored on your device by your browser. This Website collects cookies. Please visit our Cookie Policy to learn more about what cookies we collect, why we collect them, and how to change your cookie settings.
Children's privacy
This Website is intended for use by a general audience and does not offer services to children. Should a child whom we know to be under 18 send personal information to us, we will use that information only to respond to that child to inform him or her that they cannot use this Website.
Analytics programs
This Website uses Google Analytics to collect information about you and your behaviors. If you would like to opt out of Google Analytics, please visit
https://tools.google.com/dlpage/gaoptout/
.
Information retention
We retain all of the information that we collect until we no longer require your information to service your account or legal time limits reach their expire dates.
Direct marketing
We use the information that we collect about you for direct marketing purposes. Direct marketing is the act of selling products or services directly to consumers rather than through retailers. Residents of Australia and/or the United Kingdom - You may, at any time, request that we cease to use your information for direct marketing purposes by emailing us at
Automated decision-making
We use the information that we collect about you for automated individual decision-making. Automated individual decision-making is making a decision solely by automated means without any human involvement.
We use the logic below to conduct automated decision-making:
scoring for intent based marketing
Your rights
Depending upon where you reside, you may have the following rights with regard to your personal information:
The right to access the personal information that we have collected about you.
Applies To
Residents of Canada, Australia, the United Kingdom, and Quebec only
The right to say no to the sale of your personal information.
Applies To
Residents of Nevada only
The right to request that we delete all or some of the personal information that we have collected on you.
Applies To
Residents of the United Kingdom only
The right to ask us to transmit your personal information that we have collected on you to another provider (where technically feasible)..
Applies To
Residents of the United Kingdom only
The right to request that we amend any of the information that we have collected about you.
Applies To
Residents of Canada, Australia, the United Kingdom, and Quebec only
The right to withdraw your consent to the processing of your data.
Applies To
Residents of Canada, Australia, the United Kingdom, and Quebec only
The right to request that we restrict the processing of your data.
Applies To
Residents of the United Kingdom only
The right to lodge a complaint regarding our collection, sharing and processing of data with competent authorities in the proper jurisdiction.
Applies To
Residents of Canada, Australia, the United Kingdom, and Quebec only
The right to not have to identify yourself, or of using a pseudonym in certain circumstances.
Applies To
Residents of Australia only
The right to stop receiving unwanted direct marketing.
Applies To
Residents of Australia only
The right to opt out of the use of your data for automated decision making purposes.
Applies To
Residents of Quebec only
Exercising your rights
You may exercise the rights specified above by submitting a consumer request to:
You may exercise the rights specified above by submitting a consumer request to:
Thomas Henderson
(267) 825-3518
1600 Union Meeting Road , Blue Bell PA 19422
We will need to verify your identity prior to effectuating your request. To verify your identity, you will need to provide us with the following information with your request:
Name;
Billing address;
Phone number;
Email address.
Please note that we may be unable to process your request if you do not provide us with the above information.
We will respond to most consumer requests within 30 to 45 days of receipt, depending upon where you reside. However, some requests may take longer. We will notify you in writing if we need more time to respond. We have the ability to deny your request(s) if certain exceptions in the law apply. If we do deny your request, we will provide you with the reasons for such denial.
Complaints
You have the right to lodge a complaint regarding our collection, use and sharing of your personal information by contacting us at the following contact information:
Thomas Henderson
(267) 825-3518
1600 Union Meeting Road , Blue Bell PA 19422
Any such complaints must first be addressed to us in writing as required by Australia Privacy Act 1988 S 40(1A). We will respond to all complaints within a reasonable time (usually 30 days). If you are not satisfied with our response to your complaint, you may then lodge a complaint with the Office of the Australian Information Commissioner by following the steps on
this page.
Accountability
The following person is accountable and responsible for our privacy practices and procedures:
Thomas Henderson
(267) 825-3518
You may lodge a complaint with us by contacting the person accountable and responsible for our privacy practices and procedures at the contact information above. Residents of Quebec may lodge a complaint with the Office of the Privacy Commissioner of Quebec by filling out
this form or calling 1-888-528-7741. Residents of Canada may also lodge a complaint with the Office of the Privacy Commissioner of Canada by visiting this page or calling 1-800-282-1376.
Location of data processing
All data processing activities undertaken by us take place in United States.
Do Not Track
Do Not Track is a preference you can set on your browser to inform websites that you do not want to be tracked. We do not support Do Not Track ("DNT"). You can either enable or disable Do Not Track by visiting the Preferences or Settings page of your browser.
Changes to Privacy Policy
We reserve the right to amend this Privacy Policy at any time. We will notify you of any changes to this Privacy Policy by posting the updated Privacy Policy to this website or application.
Questions
If you have any questions about this Privacy Policy, please contact us at [email protected].
