Privacy policy

Panoptyc, Inc.’s Privacy and Biometric Data Policy

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Panoptyc, Inc. (“Panoptyc,” “Company,” “we,” “us,” “our”) provides a website located at panoptyc.co (“Website”) as well as products, services, and other offerings associated with camera inventory management and theft prevention (collectively, the “Services”). This privacy policy (“Policy”) describes the way Panoptyc collects, uses, maintains, and discloses information when you visit our Website or interact with our Services.
By visiting our Website or interacting with our Services, you agree to this Policy. If you do not agree to be bound by this Policy, you may not access our Website or interact with our Services.

THIS PRIVACY POLICY CONTAINS A BIOMETRIC DATA PRIVACY POLICY (“BIOMETRIC DATA POLICY”). BY USING OUR WEBSITE OR INTERACTING WITH OUR SERVICES, YOU EXPRESSLY AGREE TO OUR BIOMETRIC DATA POLICY.
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BIOMETRIC DATA POLICY.

Definitions.

“Biometric Data” means “Biometric Identifiers” and “Biometric Information” unless otherwise defined by applicable law.

“Biometric Identifiers” means (without limitation) retina or iris scans, fingerprints, voiceprint, or scan of hand or face geometry, as well as data generated by automatic measurements of an individual’s biological characteristics or other unique biological patterns that is used to identify a specific individual.

“Biometric Information” means any information, regardless of how it is captured, converted, stored or shared, based on an individual’s Biometric Identifier used to identify an individual. Biometric Information does not include information derived from items or procedures that are not Biometric Identifiers.

“Facial Template” means the algorithmic and encrypted representation of measurements between variable points on a user’s face, resulting in a unique template that may be used to later identify and authenticate the individual based on the capture of a subsequent Facial Template. The Facial Template is only usable and readable by certain technology.

Panoptyc uses Facial Templates in limited states.
Panoptyc utilizes Facial Templates in limited states in order to provide its Services, as discussed in more detail below. Facial Templates cannot be reverse engineered to be usable outside of Panoptyc’s ecosystem. In certain jurisdictions, Facial Templates may constitute Biometric Data.
Panoptyc’s use of Facial Templates is subject to Panoptyc’s Privacy Policy and this Biometric Data Policy. Where inconsistent, the terms of this Biometric Data Policy control.

RESIDENTS OF CANADA, ILLINOIS, WASHINGTON, TEXAS, OREGON, NEW YORK, OR VIRGINIA, AND OTHER STATES OR JURISDICTIONS THAT PROHIBIT THE COLLECTION OF BIOMETRIC DATA. 
WHERE THERE IS A JURISDICTION WITH LAWS THAT PROHIBITS THE COLLECTION OF BIOMETRIC DATA OR INFORMATION, WE DO NOT POSSESS, STORE, COLLECT, CAPTURE, PURCHASE, RECEIVE THROUGH TRADE, OR OTHERWISE OBTAIN FACIAL TEMPLATES, BIOMETRIC IDENTIFIERS, OR DATA THAT CAN BE CLASSIFIED ASBIOMETRIC INFORMATION. WE DO NOT UTILIZE FACIAL TEMPLATE OR BIOMETRIC DATA TECHNOLOGIES IN THE STATES OF ILLINOIS, WASHINGTON, TEXAS, OREGON, NEW YORK, OR VIRGINIA, OR ANY OTHER JURISDICTION WITH LAWS THAT PROHIBIT THE COLLECTION OF BIOMETRIC DATA OR INFORMATION.

How Facial Templates are collected and used.
Our retail partners in certain states may use our Services that utilize Facial Template technologies in order to detect and prevent theft and fraudulent activity at their micro market and self-service retail locations. When you interact with our Services through our partners using Facial Template technology, your Facial Template may be collected and used. When this happens, our automated camera will take several measurements between various points on your face. The measurements are then input into an algorithm which generates a unique and encrypted representation of the measures, i.e. a Facial Template. When you next interact with our Services through our retail partners, the previously created Facial Template may be used to identify or designate you as a match. Panoptyc’s proprietary technology analyzes Facial Template event data and other variables in order to detect and prevent theft and other forms of retail fraud.
This Biometric Data Policy does not apply to Facial Templates or Biometric Data that have been de-identified and aggregated and which are no longer capable of identifying a natural person. We may use, retain, and share such de-identified and aggregated Facial Templates or Biometric Data for any purpose.

Limitations on use of Facial Templates.
Except as set forth in our Biometric Data Policy, Panoptyc does not and will not (i) collect, capture, purchase, receive through trade or otherwise buy Facial Templates or Biometric Data; (ii) disclose, re-disclose or otherwise disseminate Facial Templates or Biometric Data; (iii) use or disclose Facial Templates or Biometric Data in a manner materially inconsistent with this Biometric Data Policy; or (iv) sell, lease, trade and otherwise transfer your Facial Templates or Biometric Data to third parties, without providing you with advance written notice and obtaining your affirmative prior consent.

Exceptions. Panoptyc may share Facial Templates or Biometric Data without prior notice or consent only when required to: (i) comply with applicable law; (ii) respond to a valid warrant or subpoena; (iii) complete a transaction you authorized or requested; or (iv) engage in other activities permitted by applicable law. We do not provide personally identifiable information, Facial Templates, or Biometric Data to third parties for marketing, advertising or other uses.

Storage, retention, and disposal of Facial Templates.
Storage. Panoptyc will store and protect Facial Templates using the reasonable standard of care within its industry and taking into account applicable privacy laws and reasonable administrative, technical, and physical controls.

Retention and Disposal. Panoptyc shall retain your Facial Template for as long as you continue to interact with our Services through your interactions with our partners utilizing Panoptyc in applicable jurisdictions. We will permanently destroy your Facial Template upon the earlier of:

  • Your request for disposal;
  • Within one year of your last interaction with our Services; or
  • When required by law.

Opting Out.
If you decide that you no longer consent to our Biometric Data Policy, you may opt-out of Biometric Data or Facial Template enabled identification by notifying us in writing via the contact information provided in this Privacy Policy.
When you opt-out, we will de-identify any Facial Template previously associated with you and aggregate it with other de-identified Facial Templates into our opt-out pool. The next time you interact with our Facial Template technology, the system will recognize that your Facial Template is part of the opt-out pool. Once the system recognizes that your Facial Template is part of the opt-out pool, no identification or further recognition is conducted on your Facial Template, and the Facial Template is immediately deleted from our system.

Miscellaneous.

Dispute Resolution. You agree that all disputes, controversies, and claims between you and us, or any of our partners in connection with your interactions with our Services at our partners’ retail locations, including in relation to this Biometric Data Policy or any dispute, controversy, or claim in connection with us or our partners’ possession, storage, collection, capturing, use, or sharing of Facial Templates or Biometric Data SHALL TO THE EXTENT PERMITTED BY LAW BE RESOLVED THROUGH BINDING ARBITRATION ON AN INDIVIDUAL BASIS AND NOT IN A COURT OF LAW OR THROUGH CLASS/COLLECTIVE PROCEEDINGS. Dispute Resolution and Arbitration procedures may be accessed or initiated by contacting us using the procedures set forth below.

Limitations of Liability. YOU AGREE TO RELEASE US FROM, ANY DAMAGES, INCLUDING, BUT NOT LIMITED TO, ANY DIRECT, SPECIAL, STATUTORY, INDIRECT, OR CONSEQUENTIAL DAMAGES INCURRED OR SUFFERED AS A RESULT OF OR RELATED TO YOUR INTERACTION WITH OUR SERVICES.

Severability. Any part, provision, representation or warranty of Panoptyc’s Biometric Data Policy which is found or held to be void or unenforceable shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions of the Biometric Data Policy.

GENERAL PRIVACY POLICY PROVISIONS
Panoptyc’s Privacy Policy describes how we collect, hold and use information about individuals who visit the Website that is capable of identifying those individuals (“Personal Information”).
By using any part of the Website, including by submitting a form or information request, (by any means, whether in correspondence, via our Website or otherwise) you accept the terms of this Policy. Any reference to our Website includes its e-mail, text, live chat, and other electronic messages. If you do not agree with this Policy or our practices, you may not use our Website. This Policy may change from time to time. Your continued use of our Website constitutes your acceptance of those changes. We encourage you to review this Policy periodically.
Please contact us using the email, phone number or form on our Contact page if you have any questions about this Policy.

Information Collected
WE COLLECT PERSONAL INFORMATION ABOUT YOU IN VARIOUS WAYS, SUCH AS WHEN YOU PROVIDE IT ON OUR WEBSITE OR AFFILIATED WEBSITES,  SOCIAL MEDIA CHANNELS, AT OUR EVENTS, VISITS TO OUR CUSTOMERS, THROUGH YOUR PARTICIPATION IN WEBINARS AND SURVEYS, AND VIA CHAT MESSAGES OR ON THE TELEPHONE. WE MAY COLLECT AND USE THE FOLLOWING PERSONAL INFORMATION:

  • Contact information (such as full name, postal address, delivery address, phone number, and email address);
  • username if you have registered an account with us;
  • If you choose to purchase our Services, we may also collect certain transaction and interaction information such as customer account information, qualification data, purchase history and related records (returns, product service records, records of payments, credits, payment information (such as your payment card number, expiration date, authorization number or security code, delivery address, and billing address);
  • purchase, return, and transaction information including cart information;
  • customer service information (such as customer service inquiries, comments and history);
  • device and browsing information (such as IP address, browser type and settings, device ID, and operating system);
  • Content captured and recorded from our Products and Services, such as video recordings, live video streams, and images;
  • photographs, comments and other content you provide;
  • social media information (such as profile, username, contact information, and post history);
  • contact information you provide about friends or other people you would like us to contact; and
  • information we may obtain from third parties .

With the exception of biometric data, we do not collect, use, or process Personal Information which is classified as sensitive information under certain US or foreign legislation, such as information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, geolocation, or information of a known child. Do not provide us with any sensitive information without first obtaining written consent. 

ADDITIONALLY, WHEN YOU VISIT THE WEBSITE OR INTERACT WITH OUR RELATED TOOLS, WIDGETS OR PLUG-INS, WE MAY COLLECT SOME BASIC INFORMATION BY AUTOMATED MEANS SUCH AS COOKIES, WEB BEACONS AND WEB SERVER LOGS. THE INFORMATION WE COLLECT IN THIS MANNER MAY INCLUDE YOUR BROWSER TYPE, IP ADDRESS, INTERNET SERVICE PROVIDER’S DOMAIN NAME, WHICH PAGES YOU ACCESSED ON THE WEBSITE, AND WHEN, UNIQUE DEVICE IDENTIFIER, BROWSER CHARACTERISTICS, DOMAIN AND OTHER SYSTEM SETTINGS, SEARCH QUERIES, DEVICE CHARACTERISTICS, OPERATING SYSTEM TYPE, LANGUAGE PREFERENCES, REFERRING URLS, ACTIONS TAKEN ON OUR WEBSITE, DATES AND TIMES OF WEBSITE VISITS, METADATA AND OTHER INFORMATION ASSOCIATED WITH OTHER FILES STORED ON YOUR DEVICE. 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. WE MAY LINK CERTAIN DATA ELEMENTS WE HAVE COLLECTED THROUGH AUTOMATED MEANS, SUCH AS YOUR BROWSER INFORMATION, WITH OTHER INFORMATION WE HAVE OBTAINED ABOUT YOU FOR THE PURPOSES DESCRIBED BELOW, AND TO LET US KNOW, FOR EXAMPLE, WHETHER YOU HAVE OPENED AN EMAIL WE SENT TO YOU. WHILE YOU CAN CHANGE YOUR COOKIES SETTINGS IN YOUR BROWSER, PLEASE NOTE, HOWEVER, THAT WITHOUT COOKIES YOU MAY NOT BE ABLE TO USE ALL OF THE FEATURES OF OUR WEBSITE.
IN ADDITION, WE MAY USE LOCAL SHARED OBJECTS TO COLLECT AND STORE INFORMATION ABOUT YOUR PREFERENCES AND HOW YOU INTERACT WITH OUR WEBSITE. THESE TECHNOLOGIES HELP US RECOGNIZE YOU, CUSTOMIZE OR PERSONALIZE YOUR SHOPPING EXPERIENCE, STORE ITEMS IN YOUR ONLINE SHOPPING CART BETWEEN VISITS, AND ANALYZE THE USE OF OUR SERVICES AND SOLUTIONS TO MAKE THEM MORE USEFUL TO YOU. THESE TECHNOLOGIES ALSO ALLOW US TO AGGREGATE DEMOGRAPHIC AND STATISTICAL DATA AND COMPILATIONS OF INFORMATION, WHICH MAY INCLUDE PERSONAL INFORMATION, AND SHARE THIS INFORMATION WITH OUR BUSINESS PARTNERS AND SERVICE PROVIDER THAT PROVIDE PRODUCTS AND SERVICES TO US.
WE MAY ALSO OFFER INTERNET-BASED ADVERTISING PROGRAMS ON OUR WEBSITE SUCH AS NETWORK ADVERTISING (HTTP://WWW.NETWORKADVERTISING.ORG/) AND ADCHOICES (HTTP://YOURADCHOICES.COM). THESE THIRD-PARTY SERVICES SELECTIVELY DISPLAY ADS BASED ON BROWSING HISTORY. YOU CAN OPT OUT OF THESE SERVICES BY CLICKING ON THE LINKS ABOVE.
WE ALSO MAY COLLECT INFORMATION ABOUT THE LOCATION OF THE MOBILE DEVICE OR TABLET USED TO ACCESS THE WEBSITE (“LOCATION DATA”). LOCATION DATA INCLUDES: (A) THE LOCATION OF THE MOBILE DEVICE OR TABLET DERIVED FROM GPS OR WIFI USE; (B) THE IP ADDRESS OF THE MOBILE DEVICE OR TABLET OR INTERNET SERVICE USED TO ACCESS THE WEBSITE; AND (C) OTHER INFORMATION MADE AVAILABLE BY A USER OR OTHERS THAT INDICATES THE CURRENT OR PRIOR LOCATION OF THE USER, SUCH AS GEOTAG INFORMATION IN PHOTOGRAPHS. WE WILL INFORM YOU IF A SPECIFIC WEBSITE, OR SERVICE COLLECTS PRECISE LOCATION DATA. IF YOU DO NOT WANT US TO COLLECT LOCATION DATA FROM YOUR DEVICE, PLEASE DISABLE THE LOCATION SETTINGS ON YOUR DEVICE OR TABLET. NOTE,
HOWEVER, THAT DISABLING THE LOCATION SETTING MAY AFFECT YOUR ABILITY TO ACCESS AND USE OUR WEBSITE.
WHEN YOU CONNECT WITH SOCIAL MEDIA THOUGH THE WEBSITE, YOU MAY LINK WITH SOCIAL MEDIA PLATFORMS AND SOCIAL MEDIA PLUG-INS (E.G., THE FACEBOOK “LIKE” BUTTON, “SHARE TO TWITTER” BUTTON) (COLLECTIVELY, “SOCIAL MEDIA”). WHEN ACCESSING SERVICES THROUGH A FACEBOOK OR OTHER SOCIAL MEDIA ACCOUNTS, WE MAY (DEPENDING ON THE APPLICABLE USER PRIVACY SETTINGS) AUTOMATICALLY HAVE ACCESS TO INFORMATION PROVIDED TO OR THROUGH THE SOCIAL MEDIA PLATFORM. WE MAY COLLECT AND USE THIS INFORMATION FOR THE PURPOSES DESCRIBED IN THIS POLICY OR AT THE TIME THE INFORMATION IS COLLECTED.INFORMATION COLLECTED DIRECTLY BY THE THIRD PARTY PROVIDERS OF THE FEATURES IS SUBJECT TO THE PRIVACY POLICIES OR NOTICES OF THESE PROVIDERS. WE ARE NOT RESPONSIBLE FOR THESE PROVIDERS’ INFORMATION AND PRIVACY PRACTICES.
INFORMATION WE COLLECT WILL ONLY BE USED AS DESCRIBED IN THIS POLICY. IF YOU CHOOSE NOT TO PROVIDE CERTAIN INFORMATION, WE MAY NOT BE ABLE TO PROVIDE YOU WITH REQUESTED PRODUCTS, SERVICES OR INFORMATION.

How Data is Used/Third Parties
WE WILL USE YOUR PERSONAL INFORMATION AS DESCRIBED ABOVE TO CONTACT YOU REGARDING YOUR INTEREST IN THE PANOPTYC SERVICES AND FOR SYSTEMS ADMINISTRATION AND TROUBLESHOOTING PURPOSES. WE MAY ALSO USE YOUR PERSONAL INFORMATION TO FULFILL OUR BUSINESS RELATIONSHIP WITH YOU, INCLUDING CUSTOMER SERVICE, AND IN ONE OR MORE OF THE FOLLOWING WAYS, AND WE MAY SEEK SPECIFIC CONSENT PRIOR TO SUCH USE, DEPENDING ON YOUR JURISDICTION. IN THE PAST TWELVE MONTHS, WE HAVE USED PERSONAL INFORMATION TO:

  • to prevent and detect fraud and other unlawful activity, claims and other liabilities;
  • to improve or develop new services and product offerings;
  • to identify, offer, and contact you with personalized content and advertising, including newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information;
  • to conduct market research, surveys, and similar inquiries to help us understand trends and customer needs across product categories or customer groups;
  • to alert you about a product safety announcement or recall or correction of an offer, promotion, or advertisement;
  • to enroll you in loyalty or other programs, and enter you into sweepstakes and promotions or contact you regarding a contest prize;
  • to keep a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online;
  • to notify you of changes to our Website or any products or Services we offer;
  • for marketing and promotional purposes;
  • to verify and validate your identity to reduce credit risk and manage collections;
  • to ensure that your shopping experience is as easy and pleasant as possible;
  • to carry out our obligations and enforce our rights; 
  • carry out the activities detailed in the Biometric Data Policy;
  • to comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.

WE MAY ALSO USE THE INFORMATION IN OTHER WAYS FOR WHICH WE DESCRIBE AT THE TIME OF COLLECTION.
IN ADDITION, WE MAY USE INFORMATION COLLECTED THROUGH COOKIES, WEB BEACONS, PIXELS, WEB SERVER LOGS AND OTHER AUTOMATED MEANS FOR PURPOSES SUCH AS (A) CUSTOMIZING OUR USERS’ VISITS TO OUR WEBSITE, (B) DELIVERING CONTENT TAILORED TO OUR USERS’ INTERESTS AND THE MANNER IN WHICH OUR USERS BROWSE OUR WEBSITE, AND (C) MANAGING OUR WEBSITE AND OTHER ASPECTS OF OUR BUSINESS. TO THE EXTENT REQUIRED BY APPLICABLE LAW, WE WILL OBTAIN YOUR CONSENT BEFORE COLLECTING INFORMATION USING COOKIES OR SIMILAR AUTOMATED MEANS.
WE MAY USE THIRD-PARTY ANALYTICS SERVICES ON OUR WEBSITE, SUCH AS:

  • Google Analytics. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze your use of our Website. The information collected through these means (including IP address) may be used by these analytics providers and other relevant third parties who use the information, for example, to evaluate use of the Website. To learn more about these analytics services and how to opt out, please visit the relevant website listed above or click here to learn about our partners participating in the Digital Advertising Alliance.

Internet-Based Advertising
 IN THE PAST TWELVE MONTHS, WE HAVE COLLECTEDINFORMATION ABOUT YOUR ONLINE ACTIVITIES THAT IS CONSIDERED SHARING UNDER CERTAIN DATA PROTECTION LAWS FOR USE IN PROVIDING YOU WITH ADVERTISING ABOUT PRODUCTS AND SERVICES TAILORED TO YOUR INDIVIDUAL INTERESTS. THIS SECTION OF OUR POLICY PROVIDES DETAILS AND EXPLAINS HOW TO EXERCISE YOUR CHOICES.
YOU MAY SEE OUR ADS ON OTHER WEBSITES BECAUSE WE USE THIRD-PARTY AD NETWORKS, SUCH AS THE FOLLOWING, TO SERVE OUR ADS:

THROUGH SUCH AD NETWORKS, WE CAN TARGET OUR MESSAGING TO USERS THROUGH DEMOGRAPHIC, INTEREST-BASED AND CONTEXTUAL MEANS. WE MAY ALSO USE OUR OWN COOKIES TO SERVE YOU RELEVANT ADVERTISING FROM WHICH YOU CAN OPT OUT OF BY CLICKING THE LINKS ABOVE. WE CAN TRACK YOUR ONLINE ACTIVITIES OVER TIME BY COLLECTING INFORMATION THROUGH AUTOMATED MEANS, INCLUDING THROUGH THE USE OF FIRST AND THIRD-PARTY COOKIES, WEB SERVER LOGS, PIXELS AND WEB BEACONS. THE NETWORKS USE THIS INFORMATION TO SHOW YOU ADVERTISEMENTS THAT MAY BE TAILORED TO YOUR INDIVIDUAL INTERESTS. THE INFORMATION OUR AD NETWORKS MAY COLLECT ON OUR BEHALF INCLUDES DATA ABOUT YOUR VISITS TO WEBSITES THAT SERVE OUR ADVERTISEMENTS, SUCH AS THE PAGES OR ADVERTISEMENTS YOU VIEW AND THE ACTIONS YOU TAKE ON THE WEBSITES. THIS DATA COLLECTION TAKES PLACE BOTH ON OUR WEBSITE AND ON THIRD-PARTY WEBSITES 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, CLICK ON THE LINKS ABOVE OR CLICK HERE TO LEARN ABOUT OUR PARTNERS PARTICIPATING IN THE DIGITAL ADVERTISING ALLIANCE.

Security Measures
WE PROVIDE COMMERCIALLY REASONABLE PHYSICAL, ELECTRONIC, AND PROCEDURAL SAFEGUARDS TO PROTECT YOUR PERSONAL INFORMATION. FOR EXAMPLE, WE LIMIT ACCESS TO THIS INFORMATION TO AUTHORIZED EMPLOYEES, SERVICE PROVIDERS, AND CONTRACTORS WHO NEED ACCESS TO PERFORM THE ACTIVITIES DESCRIBED IN THIS POLICY. WHILE WE STRIVE TO SAFEGUARD YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE THE SECURITY OF ANY INFORMATION YOU DISCLOSE OR TRANSMIT TO US.
IF YOU RECEIVE AN E-MAIL THAT LOOKS LIKE IT IS FROM US ASKING YOU FOR YOUR PERSONAL INFORMATION, DO NOT RESPOND. WE WILL NEVER REQUEST YOUR PASSWORD, USERNAME, CREDIT CARD INFORMATION, OR OTHER PERSONAL INFORMATION THROUGH E-MAIL.

Log Files
PANOPTYC RESERVES THE RIGHT TO USE INTERNET PROTOCOL ADDRESSES, I.E. “IP ADDRESSES,” TO ANALYZE TRENDS, ADMINISTER THE WEBSITE AND ESTIMATING TOOLS, TRACK USER ACTIVITIES, IMPROVE FEATURES AND SERVICES AND GATHER BROAD DEMOGRAPHIC INFORMATION FOR AGGREGATE USE. IP ADDRESSES ARE NOT LINKED TO SPECIFIC CONSUMERS AND CANNOT BE USED TO IDENTIFY SPECIFIC CONSUMERS. ADDITIONALLY, FOR SYSTEMS ADMINISTRATION, DETECTING USAGE PATTERNS AND TROUBLESHOOTING PURPOSES, OUR WEB SERVERS MAY LOG CERTAIN NON-PERSONAL ACCESS INFORMATION INCLUDING BROWSER TYPE, ACCESS TIMES AND REQUESTED OR REFERRED URLS. THIS INFORMATION IS NOT SHARED WITH THIRD PARTIES, EXCEPT ON OCCASION IN ANONYMOUS, AGGREGATE FORM, AND IS DISCLOSED AMONG PANOPTYC PERSONNEL ONLY ON A NEED-TO-KNOW BASIS. ANY PERSONAL INFORMATION RELATED TO THIS DATA WILL NEVER BE USED IN ANY WAY DIFFERENT TO THAT STATED ABOVE WITHOUT YOUR EXPLICIT PERMISSION.

Use of Cookies
LIKE MOST INTERACTIVE WEB SITES, THE WEBSITE MAY USE COOKIES TO ENABLE THE RETRIEVAL OF USER DETAILS FOR EACH VISIT. COOKIES MAY BE USED IN SOME AREAS OF OUR WEBSITE TO ENABLE FUNCTIONALITY AND EASE OF USE FOR THOSE PEOPLE VISITING.

Disclosure of Information
WE DO NOT DISCLOSE PERSONAL INFORMATION WE COLLECT ABOUT YOU, EXCEPT AS DESCRIBED IN THIS POLICY. WE MAY SHARE PERSONAL INFORMATION WITH SERVICE PROVIDERS WHO PERFORM SERVICES ON OUR BEHALF. THE TERM “SERVICE PROVIDER” SHALL HAVE THE MEANING GIVEN TO IT UNDER THE CALIFORNIA CONSUMER PRIVACY ACT OF 2018 (CALIFORNIA CIVIL CODE §§ 1798.100 TO 1798.198) THESE SERVICE PROVIDERS ARE PERMITTED TO USE OR DISCLOSE THE INFORMATION ONLY AS NECESSARY TO PERFORM SERVICES ON OUR BEHALF OR COMPLY WITH LEGAL REQUIREMENTS. EXAMPLES OF THESE SERVICE PROVIDER INCLUDE ENTITIES THAT PROCESS CREDIT CARD PAYMENTS, MANAGE AND REDUCE OUR CREDIT RISK, VERIFY INFORMATION, FULFILL ORDERS, AND PROVIDE WEB HOSTING, ANALYTICS AND MARKETING SERVICES. WE ALSO MAY SHARE YOUR PERSONAL INFORMATION WITH OUR AFFILIATES AND JOINT MARKETING PARTNERS FOR THE PURPOSES DESCRIBED IN THIS POLICY.
WE MAY RELEASE YOUR PERSONAL INFORMATION IF WE ARE REQUIRED TO DO SO BY LAW OR COURT ORDER OR IF WE BELIEVE IN GOOD FAITH THAT SUCH RELEASE IS NECESSARY OR APPROPRIATE TO PROTECT THE RIGHTS, PROPERTY, OR SAFETY OF OUR COMPANY, CUSTOMERS, AFFILIATES, OR OTHERS. WE MAY ALSO SHARE OR TRANSFER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, IN CONNECTION WITH THE SALE, TRANSFER, ACQUISITION, MERGER, ACQUISITION, DIVESTITURE, RESTRUCTURING, REORGANIZATION, DISSOLUTION, BANKRUPTCY OR OTHER CHANGE OR OWNERSHIP OR CONTROL BY PANOPTYC OR ANY AFFILIATED COMPANY (IN EACH CASE, WHETHER IN WHOLE OR IN PART). WHEN ONE OF THESE EVENTS OCCURS, WE WILL USE REASONABLE EFFORTS TO NOTIFY USERS BEFORE INFORMATION IS TRANSFERRED OR BECOMES SUBJECT TO DIFFERENT PRIVACY PRACTICES.
WE MAY ALSO SHARE INFORMATION OR DATA IN A FORM THAT CANNOT BE USED TO UNIQUELY IDENTIFY OR CONTACT AN INDIVIDUAL PERSON (“NON-PERSONAL INFORMATION”). WE MAY COLLECT, USE, TRANSFER, AND DISCLOSE THIS NON-PERSONAL INFORMATION FOR ANY PURPOSES. NON-PERSONAL INFORMATION THAT WE COLLECT MAY INCLUDE INFORMATION REGARDING YOUR ACTIVITIES ON THE WEBSITE, WHICH MAY BE AGGREGATED AND USED TO HELP US PROVIDE MORE USEFUL INFORMATION TO OUR CUSTOMERS AND TO UNDERSTAND WHICH PARTS OF THE WEBSITE ARE OF MOST INTEREST.

Sale of Personal Information 
In the past twelve months, we have not disclosed Personal Information obtained from consumers to certain third parties in exchange for monetary or other consideration. However, our use of cookies and other website tracking technologies may be considered a sale or sharing of Personal Information under certain data protection laws, in which case the categories of Personal Information that we have sold or shared include identifiers (e.g., IP addresses) and internet or other similar network activity. Categories of third parties to whom Personal Information is sold or shared include data analytics providers and advertising and marketing providers. For the avoidance of doubt, we have not sold Personal Information of children under the age of 16.

Data Transfer and Storage
Information we collect about you may be transferred, processed, and/or accessed by us in the United States, or another country where we or our service providers operate. Please be aware your Personal Information may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. 
If you are located outside the United States and choose to allow us to collect information about you, please be aware that we may transfer your Personal Information to the United States and process and store it there. 
If you are located in the European Economic Area (“EEA”) or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Policy.

Do Not Track Policy
SOME BROWSERS HAVE A “DO NOT TRACK” FEATURE THAT LETS YOU TELL WEBSITES THAT YOU DO NOT WANT YOUR ONLINE ACTIVITIES TRACKED. AT THIS TIME, THE WEBSITE DOES NOT RESPOND TO WEB BROWSER “DO NOT TRACK” REQUESTS.

Global Privacy Controls
Global Privacy Control (GPC) is a special browser setting that helps user’s exercise their rights or share privacy preferences. The GPC sends signals such as not to share or sell Personal Information without their consent. You can download the GPC browser extension here.

Consent
BY VISITING   THE WEBSITE OR ENTERING AN AREA WITH SIGNAGE INFORMING YOU OF THESE POLICIES YOU ARE CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION AS DESCRIBED IN THIS POLICY. YOU MAY WITHDRAW YOUR CONSENT AT ANY TIME BY CONTACTING US AT support@panoptyc.co.

Financial Incentive Notice
We may offer you certain benefits in connection with the disclosure of Personal Information and data associated with your accounts, such as the opportunity to be eligible for certain perks and benefits such as rewards, exclusive offers, and discounts. All benefits are free of charge.
When you participate in these perks and benefits, we will collect and keep the Personal Information you provide, or that you’ve previously provided, including your date of birth, country, and email address, which are required. To enhance your experience in any reward or incentive, and to provide you with tailored benefits, we may also collect and use the following categories of Personal Information listed in connection with your accounts, including Personal Information we’ve previously collected about you: 

  • Identifiers
  • Protected classifications
  • Additional Data Subject to Cal. Civ. Code § 1798.80
  • Online activity information
  • Geolocation data
  • Commercial information
  • Inferences

We collect this information through your interactions with us and our partners, as further detailed in our Privacy Policy. 

Incentives. The benefits are reasonably related to our good-faith estimate of the value provided to the use of Personal Information. The value of Personal Information to us varies by individual and is related to the value of the rewards and discounts provided to accountholders, minus the costs of providing those benefits.

How to Opt-in or Withdraw from Participation. You may withdraw from participation from any rewards program at any time by following the instructions provided upon enrollment.

Links to Third Party Sites and Services
THIS WEBSITE MAY CONTAIN LINKS TO THIRD PARTY WEBSITES OPERATED BY INDIVIDUALS OR COMPANIES UNRELATED TO US. PLEASE BE AWARE THAT WE ARE NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OF SUCH THIRD PARTY WEBSITES. WE PROVIDE LINKS TO THESE WEBSITES FOR YOUR CONVENIENCE ONLY AND YOU ACCESS THEM AT YOUR OWN RISK. WE RECOMMEND THAT YOU REVIEW THE PRIVACY POLICIES AND TERMS OF USE POSTED ON AND APPLICABLE TO SUCH THIRD PARTY WEBSITES PRIOR TO UTILIZING THEM.

Access and Retention
IF YOU HAVE A WEBSITE ACCOUNT, YOU CAN LOG IN TO VIEW AND UPDATE YOUR ACCOUNT INFORMATION. YOU MAY ALSO CONTACT US WITH REQUESTS FOR INFORMATION, QUESTIONS OR CONCERNS, TO REQUEST EDITS TO YOUR PERSONAL INFORMATION, OR TO HAVE YOUR PERSONAL INFORMATION REMOVED FROM OUR DATABASE. WE KEEP YOUR PERSONAL INFORMATION FOR AS LONG AS WE THINK IS NECESSARY OR ADVISABLE, AND WE RESERVE THE RIGHT TO RETAIN IT TO THE FULL EXTENT NOT PROHIBITED BY LAW.

U.S. Resident Privacy Rights
There are several consumer data protection laws that may apply to you, including California, Colorado, Connecticut, Virginia, and Utah. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances. To the extent that these laws apply, you may exercise the following rights: 

    • Right to Know and Access Information. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific Personal Information we associate with you or your account. 
    • Right to Data Portability. If you request a copy of your specific information then we will provide it in an easily accessible format.
    • Right to Deletion or Erasure. You may request that we delete the Personal Information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it. 
  • Right to Correct Information. You may request we correct or rectify inaccurate information we have collected about you.
  • Right to Limit Use of Information for Advertising. You may opt-out of our use of your Personal Information for advertising purposes.
  • Right to Withdraw Consent. You may withdraw your consent to our data privacy practices.
  • Right to Non-Discrimination. You have the right to not experience discrimination from us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our services or limiting the quality of our services. However, limiting use of, or deleting, your Personal Information may restrict the purposes or uses that rely on that information. If you need further assistance, you can contact Barnes & Thornburg through one of the channels listed below under “Contact.”

Nevada Privacy Rights. Nevada residents have the right to opt-out of the sale of their Personal Information by, emailing us (see our contact information below) and including “NV Sale Opt Out Request” in the subject line. Please note that we do not currently “sell” Personal Information as defined by Nevada law. 
PERSONAL INFORMATION

Canada Resident Privacy Rights
To the extent available by law, Canadian residents may exercise the following rights: 

    • Right to Know and Access Information. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific Personal Information we associate with you or your account. 
    • Right to Deletion or Erasure. You may request that we delete the Personal Information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it. 
  • Right to Correct Information. You may request we correct or rectify inaccurate information we have collected about you.
  • Right to Withdraw Consent. You may withdraw your consent to our data privacy practices.
  • Right to Lodge Complaints. You may lodge a complaint about our use of personal information with the data protection authority.  

Additional Privacy Choices
WE OFFER YOU CERTAIN CHOICES IN CONNECTION WITH THE PERSONAL INFORMATION WE COLLECT ABOUT YOU, SUCH AS HOW WE USE THE INFORMATION AND HOW WE COMMUNICATE WITH YOU. TO UPDATE YOUR PREFERENCES, ASK US TO REMOVE YOU FROM OUR MAILING LISTS, EXERCISE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION, OR SUBMIT A REQUEST, PLEASE CONTACT US. YOU CAN ALSO UNSUBSCRIBE FROM RECEIVING OUR EMAILS BY FOLLOWING THE “UNSUBSCRIBE” LINK PROVIDED IN OUR EMAILS. WE WILL HONOR YOUR REQUEST TO REMOVE YOU FROM OUR MAILING LISTS, BUT THERE MAY BE A DELAY BETWEEN SUBMISSION OF SUCH REQUEST AND ACTUAL REMOVAL FROM OUR MAILING LISTS, AS THESE LISTS ARE GENERATED WELL IN ADVANCE OF OUR ACTUAL MAILINGS. OPTING OUT OF COMMUNICATIONS DOES NOT AFFECT OUR COMMUNICATION WITH YOU VIA TELEPHONE OR EMAIL REGARDING YOUR ORDERS OR OTHER SALES OR SERVICE TRANSACTIONS.
PERSONAL INFORMATIONWE KEEP YOUR PERSONAL INFORMATION FOR AS LONG AS WE THINK IS NECESSARY OR ADVISABLE, AND WE RESERVE THE RIGHT TO RETAIN IT TO THE FULL EXTENT NOT PROHIBITED BY LAW.
Please include your email address, full name, and your specific information about your request(s) and, if applicable, specifically what information you do not want to receive. If you would like to update or correct your email address, street address, or other Personal Information with us, please include specific details about the information you wish to have updated or corrected.
For requests submitted by email, you must provide enough information that allows us to verify your identity. Only you or your authorized agent may make requests regarding your Personal Information. An authorized agent must have documentation that they are authorized to act on your behalf. Barnes & Thornburg will attempt to fulfill or reject your request within the amount of time required by law. 
YOU CAN CONTACT US TO EXERCISE YOUR RIGHTS PURSUANT TO THIS POLICY OR ASK QUESTIONS REGARDING THIS POLICY BY:

  • Calling us at [313-425-5765]
  • Emailing us at [support@panoptyc.co] with attention to the Privacy Officer.

Children Under Age of 13
WE ARE COMMITTED TO PROTECTING THE PRIVACY OF CHILDREN. THE WEBSITE IS NOT INTENDED FOR USE BY CHILDREN UNDER THE AGE OF 13. WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF 13. IF YOU ARE UNDER 13 DO NOT USE OUR WEBSITE OR PROVIDE ANY INFORMATION ABOUT YOURSELF INCLUDING, WITHOUT LIMITATION, YOUR NAME, ADDRESS, EMAIL ADDRESS OR ANY SCREEN NAME OR USER NAME YOU MAY USE. IF WE LEARN THAT WE HAVE COLLECTED OR RECEIVED PERSONAL INFORMATION FROM A CHILD UNDER 13 WITHOUT VERIFICATION OF PARENTAL CONSENT, WE WILL DELETE THAT INFORMATION. IF YOU BELIEVE THAT WE MAY HAVE ANY INFORMATION FROM OR ABOUT A CHILD UNDER 13, PLEASE CONTACT US AT support@panoptyc.co. PLEASE VISIT THE FTC’S WEBSITE AT WWW.FTC.GOV FOR TIPS ON PROTECTING CHILDREN’S PRIVACY ONLINE.

Modifications to this Policy
WE WILL MODIFY THIS POLICY IF OUR PRIVACY PRACTICES CHANGE. WE WILL NOTIFY YOU OF SUCH CHANGES BY POSTING THE MODIFIED VERSION ON OUR WEBSITE AND INDICATING THE DATE IT WAS LAST MODIFIED, AND, IF THE CHANGES ARE SIGNIFICANT, WE WILL PROVIDE A MORE PROMINENT NOTICE (INCLUDING BY EMAIL IN CERTAIN INSTANCES). THE DATE THIS POLICY WAS LAST MODIFIED IS BELOW.