SUBSTI2UTE, LLC
CLASSICLE PRIVACY POLICY
Last Updated August 31, 2020
Substi2ute, LLC d/b/a Classicle (“Classicle”, “we”, “us” or “our”) is committed to protecting your (“you” or “your”) privacy and empowering you with this privacy policy (this “Privacy Policy”). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use or make a purchase from our website (https://classicle.com/) (the “Site”) or use any of the other services that we may make available to you (collectively, “Services”). Our Terms of Use (the “Terms”) are expressly incorporated herein by reference and are an integral part hereof. The Terms can be found here: (https://classicle.com/terms-of-use). Other capitalized terms that are not expressly defined in this Privacy Policy have the same meaning as set forth in the Terms.
By using the Services, or interacting with us, you are agreeing to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, do not access or use the Services. Please read the following carefully to understand how we collect, use, and maintain your personal information. In addition, it describes your choices for use, access, and correction of your personal information.
2.1 Information You Provided to Us. We collect information that you decide to share with us. At times, we may require you to provide certain information in order to use certain parts of our Site, fulfill your requests, or provide you with certain Services.
2.1.1 Registering for an Account. If you establish an Account with us, we may require you to provide your name, your email address, your home address, your gender, your birthday, your phone number, and a password to create your account.
2.1.2 Billing Information. If you register for an Account and pay the Platform Fee, we will also collect your payment method details, such as account number, expiration date, and security code, as well as your billing address, for payment purposes, if not previously provided.
2.1.3 Posting an Opportunity. If you are a Client, we collect and store all of the additional information that you provide to us on your Opportunity. This may include, among other information: (i) the type of care you are looking for, your schedule, location, hourly rate, number and ages of children, family members, or pets (if applicable), narrative job description, requirements for a Care Provider; (ii) pictures you choose to provide; (iii) health information, if you choose to provide it; (iv) COVID Risk Tolerance Self-Assessment and Exposure Questionnaire scores; and (v) any other information you choose to include in your Opportunity.
2.1.4 Posting a Profile. If you are a Care Provider, we collect and store all of the additional information that you provide to us in your Account. This may include, among other information: (i) details on the care you offer, including, for example, the type of care you provide, your availability, your location, your level of education, languages you speak, and your ability to drive; (ii) related services you provide; (iii) pictures you choose to post; (iv) your phone numbers references, if you choose to provide them; and (v) any other information you choose to include in your profile
2.1.5 Content Information. You also may choose to send us personal information in an email or chat message containing inquiries about the Services and we use this information in order to help us respond to your inquiry. We also collect content within any messages you exchange with other Users through the Services.
2.2 Information We Obtain from Others.
2.2.1 From Third Parties. We may obtain information about you from third parties who help us provide our Services to you. We may also obtain some information from our marketing partners in order to inform you about products or Services that we think you might be interested in. Finally, we may obtain information that does not identify you directly, but which is later used in a way that may later directly identify you. We may combine that general information with your information to provide related services to you.
2.2.2 From Other Users of the Services. We also capture and collect information that Users provide about one another. For example, Care Providers may invite others to rate and indicate their relationship to the Care Provider on the Site. Additionally, certain Users may post reviews about individual Care Providers. In addition, Users may communicate directly with one another through the Services. Users also may provide us information about others by contacting us directly.
2.3 Information We Automatically Collect. We automatically collect certain information from you when you use the Services, including internet or other network activity information (as described below), unique device identifiers, browsing and search history (including content you have viewed in the Site), and cookies and other technologies (as defined in Section 3). Information collected automatically includes:
2.3.1 Device information. We collect technical information when you visit our Site. This includes information such as the type of device or browser you use, your device’s operating system, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id. When you visit and interact with the Services, we may collect certain information automatically through cookies or other technologies, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type(s) of internet browser(s) you use, and information about the way you use the Services.
2.3.2 Usage Information. We collect information regarding your use of the Services including data about features you use, pages you visit, emails and advertisements you view, portions of the Services that you view and interact with, the time of day you browse, and your referring and exiting pages.
2.3.3 Location Data. We collect information regarding your location during your use of the Services including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level), and, with your consent, precise location data (such as latitude/longitude data).
2.3.4 Crash and Error Information. If any of the Services crash or return an error, we may collect data to determine the cause of the error. The crash or error information collected may include the following: IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.
3.1 Cookies. Below, we explain the different types of Cookies that may be used on the Site.
3.1.1 Necessary Cookies. Necessary Cookies are essential to enable your use of the Site and to identify and prevent security risks, such as storing your session information to prevent others from changing your password without your username and password.
3.1.2 Preference Cookies. We use these Cookies to remember your settings and preferences, and to improve your experience on our Site. For example, we may use these Cookies to remember your language preferences.
3.1.3 Session Cookies. These types of Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use session Cookies to support the functionality of the Site and to understand your use of the Site—that is, which pages you visit, which links you use and how long you stay on each page.
3.1.4 Statistics Cookies. Statistics Cookies help collect information about your use of the Site and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor the Site’s performance, count page visits, spot technical errors, see how Users reach the Site, and measure the effectiveness of marketing (including emails).
3.1.5 Marketing Cookies. Marketing Cookies are used to show Users display advertisements across websites. The intention is to display ads that are relevant and engaging for the individual User and thereby more valuable for publishers and third-party advertisers. We do not display ads for any services besides our own.
3.1.6 Unclassified Cookies. Unclassified Cookies are Cookies that we are in the process of classifying, together with the providers of individual Cookies.
3.2 Other Technologies. In addition to Cookies, we may use other similar technologies, like pixel tags (also known as web beacons and clear GIFs), to, among other things, track the actions of Users of the Services (about usage including email recipients), measure the success of our marketing campaigns, and compile statistics of the Services and response rates.
(a) We may use the information collected for the limited purpose of providing the Services and related functionality and services, as described in the Terms and in this Privacy Policy, and as permitted by applicable laws. These limited purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent. We may use the information we obtain about you to:
(i) Provide the information, products and Services you request;
(ii) Service your account and provide you, if you are a registered User, with effective customer service;
(iii) Better understand your needs and interests, and provide you with a personalized experience when you use our Site;
(iv) Contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
(v) Contact you with information and notices related to your use of our Services, including our Site;
(vi) Invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
(vii) Improve our products and Services and develop new products and Services, improve our marketing and promotional efforts, and improve the content, functionality and usability of the Site;
(viii) Enforce our Terms;
(ix) Enable Clients and Care Providers to search based on the information the other has made available on the Site, and information others have provided about them, and to connect Clients with Care Providers that appear to meet their needs and preferences;
(x) Promote security and protect against and prevent fraud, claims and other liabilities;
(xi) Verify information you provide to us as well as the representations and warranties you make to us in the Terms or on the Site;
(xii) Meet our internal and external audit obligations; and
(xiii) Use for any other purpose for which we provide notice at the time of collection.
(b) We may aggregate and/or de-identify information collected through the Site and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including, without limitation, for research and marketing purposes, and we may also share such data with any third parties, including advertisers, promotional partners, business and channel partners, sponsors, and/or others.
5.1 We Do Not Sell Personal Information. We do not sell or otherwise disclose personal information we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected. We share information to perform activities that you request.
5.2 Service Providers and Business Partners. We also share information with vendors with whom we have a contractual relationship and who perform services for us including, without limitation, vendors who provide email, demographic information, or geo-location information services, vendors who process or accept credit card payments, and vendors who provide services that enable us and other third parties to detect and prevent fraud, in each case to the extent applicable. We may also share your personal information with Google Analytics, which helps us understand how our Users use our Site. You can learn about Google’s practices by going to http://www.google.com/policies/privacy/partners/, and exercise the ‘opt-out’ provided by Google by downloading the Google Analytics opt-out browser add-on, available here: https://tools.google.com/dlpage/gaoptout.
5.3 Your Consent. We may share information for other purposes pursuant to your consent or with your further direction.
5.4 With Other Users of the Site and Services. We facilitate contact between Clients and Care Providers and reserve the right to share a Care Provider’s contact information (e.g., name, phone number, email, or postal address) with a Client and vice versa in order to facilitate the performance of an Opportunity. This exchange of information is a mandatory part of the Services.
5.5 Public Areas. Your profile on the Services consists of information about you and your business, and may include information such as photographs, your years in business, skills and expertise, hourly pay rates, feedback/rating information, and other information, including your Username. The information in your profile may be visible to all Users and the general public. If you choose to post an Opportunity via the Services, the contents of such listing will be viewable to the Care Providers you select on the Services.
5.6 Legal Reasons. We may also disclose information about you when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose information about you to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Site; to enforce or apply our Terms or other agreements; or to protect our own rights or property or the rights, property or safety of our Users or others. We will attempt to notify Users about legal demands for their personal information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority.
5.7 Sale, Merger, or Other Business Transfer. We also reserve the right to transfer information about you to a successor organization if we transfer the ownership or operation of one of our websites to another organization or if we merge with another organization. If such a transfer occurs, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
(a) You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. In addition, your choice to disable Cookies is specific to the particular browser or device that you are using when you disable Cookies, so you may need to separately disable Cookies for each type of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Site may no longer be available to you.
(b) You may opt out of behaviorally targeted ads anytime by clearing your cache of your browser’s Cookies. Additionally, you may opt-out of interest-based advertising from some third-party partners by visiting http://preferences-mgr.truste.com/, or the third-party provider’s websites. Please note that opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) after you opt-out.
(c) If you have registered for an Account, you may access, review, and update certain personal information that you have provided to us by logging into your Account and using available features and functionalities.
(d) You have a choice at any time to stop us from sending you emails for marketing purposes by adjusting your settings in your account settings. You also have the option to opt out of receiving certain other emails from us by adjusting your settings in your account settings. You can also opt out of commercial email messages by following the “unsubscribe” link included in these messages. Please note that despite any indicated email marketing preferences, we may continue to send you administrative emails regarding Classicle, including, for example, notices of updates to our Terms or this Privacy Policy, notifications of new Clients or Care Providers in your area, responses to job postings from Care Providers, and responses to job applications from Care Providers, if we choose to provide such notices to you in this manner.
(e) Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
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