LDN PRIVACY POLK
Effective Date: January 1, 2020
TABLE OF CONTENTS
1. Your California Privacy Rights
2. Your European Privacy Rights
3. Information We Collect on the Website
4. How We Use Your Personally Identifiable Information and Usage Information
5. External Links
6. Public Forums/User Content
8. Updating or Deleting Your Personally Identifiable Information
9. Ad Serving
10. Google Analytics
12. Jurisdictional Issues — Consent to Transfer
13. Children’s Privacy
14. Contacting Legend
Your California Privacy Rights
Effective Date: January 1, 2020
I. Information We Collect
We have collected the following categories of information in the past 12 months:
II. Disclosure of Personal Information
We disclose personal information to our service providers and third parties, as described above.
III. Your Rights and Choices
The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Access Your Information. You have the right to request that we disclose what personal information we have collected used or disclosed over the past 12 months.
Right to Request Deletion. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exercising Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either:
· Calling us at +1 (844) 217–3923 or
· Submitting the request online here.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
If you or an authorized agent submit a consumer request up to two times in a 12-month period at the toll-free number, mailing address, or website posted above, we will respond in accordance with the CCPA:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, please contact us through the following web form: Do Not Sell My Personal Information
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.
IV. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the following web form.
V. Contact Information
If you have any questions or comments about this Notice, the ways in which we collect, use, and retain your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: +1 (844) 217–3923
2900 W. Alameda Avenue
Burbank, CA 91505
Your European Privacy Rights
We process your personal data to the extent permitted by law. Such processing may include the transfer to and storage of your data at servers outside the European Union including locations within the United States. In this context we rely on a variety of legitimate reasons for data processing including your informed consent (Article 6(1) lit. (a) GDPR), the necessity to process your personal data as part of the performance of a contract to which you are or wish to become a party (Article 6(1) lit. (b) GDPR ) and/or the necessity to process your personal data for the purposes of our legitimate interests (Article 6(1) lit. (f) GDPR ). Those interests include in particular the improvement of our services. Any personal data will only be stored on file for the time necessary to fulfill the legitimate purpose including the observance of applicable statutory requirements to maintain certain documentation of our services.
We do not share your data with any third parties unless permitted by law. However, we may involve data processors acting on our behalf and helping us to perform our contractual services.
We hereby inform you that you as the data subject have the right to request from us access to and rectification or erasure of your personal data or restriction of processing or to object to such processing as well as the right to data portability. You also have the right to lodge a complaint with the competent a supervisory authority. Further, you may at any time withdraw your once given consent. Either of those rights may be exercised by contacting us through the following web form. Please specify your demand so that we can act in accordance with your wishes.
Information We Collect on the Website
Collection of Usage Information. When users come to our Website, we automatically collect “Usage Information” which include among other things, which pages of our Website were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Website. Collecting such information may involve logging the IP address or other unique identifier (“Device Identifier”) for your computer, phone, tablet or other device used to access the Website (any, a “Device”), operating system and browser software used by each user of the Website. Although such information is not Personally Identifiable Information, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity. Whenever we associate Usage Information or a Device Identifier with your Personally Identifiable Information, we will treat it as Personally Identifiable Information.
Cookies, web beacons and embedded script allow Legend to serve you better and more efficiently, and to personalize your experience at our Website. Cookies, web beacons and embedded script are not used to retain Personally Identifiable Information. You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, certain of the functions and conveniences of this Website may not work properly, but you do not have to accept our cookies in order to use many functionalities of the Website.
California Business & Professions Code Section 22575(b)(as amended effective January 1, 2014) provides that California residents are entitled to know how Legend responds to “Do Not Track” browser settings. Legend does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
Collection of Personally Identifiable Information. In order to access certain features and benefits on our Website, you may need to submit “Personally Identifiable Information” (i.e., information that can be used to identify you). Personally Identifiable Information can include information such as your name, address, telephone number and email address as well as credit card or bank information, shipping information, and User Content (described below). You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Legend. Inaccurate information may affect your ability to use the Website, the information you receive when using the Website, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you. We may collect Personally Identifiable Information in connection with various functionality and services offered via the Website, including the following:
1. Updates and Newsletters. Legend may now, or in the future, offer you the ability to receive email updates and newsletters. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name, email address and zip code.
2. Participation in Contests, Sweepstakes, and Other Promotions. Legend may offer you the opportunity to participate in a contest, sweepstakes, or other promotions on or through the Website. If you desire to participate in any such contest, sweepstakes, or other promotion, you will be asked to provide us with certain information necessary to conduct such contest, sweepstakes, or other promotion. This information may include, among other things, your name, age, mailing address, email address, and phone number.
3. Communications with Legend. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
5. Metadata. Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted. Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other’s APIs then, your latitude and longitude will be stored with the photo and searchable (e.g., through a location or map feature) if you make your photo public by posting it on our Website.
6. Payment Information. Payment information is Personally Identifiable Information in connection with your bank, credit card, or other source of funds. Payment information may include identity verification information for purposes of fraud prevention. We may collect or receive payment information when you conduct a shopping transaction.
How We Use Your Personally Identifiable Information and Usage Information
Please take some time to familiarize yourself with the different ways Legend uses the information that we gather.
1. Usage Information. We use Usage Information in aggregate form to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Website.
3. Updates and Newsletters. We use Personally Identifiable Information collected when you sign-up for our various email, newsletter or update services to send you the messages and newsletters that you request us to send.
4. Participation in Contests, Sweepstakes and Other Promotions. We use the Personally Identifiable Information that we collect from you when you participate in a contest, sweepstakes, or other promotion through the Website for processing purposes and in connection with Winner’s lists. For instance, when a Promotion involves a users’ uploading of User Content to the Website, we may use the Metadata associated with that User Content in order to identify the source of the content and to increase its visibility for the purposes of the Promotion.
7. Disclosure to Legend Operations and Maintenance Contractors. Our operations and maintenance contractors may have access to your Personally Identifiable Information in the course of providing products or services to us. These contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Website.
9. Disclosure to Acquirers. We may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Legend to which your Personally Identifiable Information relates.
10. Administrative and Other Purposes. We may use your Personally Identifiable Information for administrative reasons, such as to contact you about Website or policy updates, or for other reasons disclosed by us when you submit your Personally Identifiable Information.
11. Payment Information. We only use payment and identity verification information as necessary to complete a particular transaction, provide a requested service, enforce legal rights or comply with applicable law.
12. Corporate Family. Your Personally Identifiable Information may also be shared with our subsidiaries and affiliates.
Public Forums/User Content
We incorporate commercially reasonable safeguards to help protect and secure your Personally Identifiable Information. However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use our Websites and provide us with your information at your own risk.
Updating or Deleting Your Personally Identifiable Information
You may unsubscribe from certain email communications by clicking the “Unsubscribe” link provided at the bottom of an email sent to you by Legend. You may also contact us through the following web form in order to delete or update your Personally Identifiable Information on our systems. We try to answer email promptly, but may not always be able to do so. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information. Please note that we reserve the right to send you certain communications relating to your use of the Website and these transactional messages may be unaffected if you choose to opt-out from marketing communications.
We may use third party network advertisers and similar vendors to serve our advertisements across the internet and third party analytics service providers to evaluate and provide us with information about the use of the Website and viewing of our content. We do not share Personally Identifiable Information with these third parties, but ad network providers and analytics service providers may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including Usage Information.
With regard to advertisements, we and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both the Website and other web sites. Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, or to conduct research regarding the usefulness of certain advertisements to you. We may share Usage Information about visitors to the Website with third party advertising companies for the same purposes. We may use a variety of companies to serve advertisements. You may wish to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding the “opt-out” procedures of certain third party ad servers we may use.
Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any prospective change, update, or modification will be effective immediately upon posting on our Website. We will not use your Personally Identifiable Information in a manner materially different than what was stated at the time it was collected without your consent.
Jurisdictional Issues — Consent to Transfer
The Website is operated in the United States and intended for users located in the United States. If you are located in the European Union, Canada or anywhere else outside of the United States, please be aware that information we collect, including, without limitation, Personally Identifiable Information, will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personally Identifiable Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Website or providing us with any information, you consent to this transfer, processing and storage of your information in the United States.
The Website is a general audience web site and we do not knowingly collect any Personally Identifiable Information from children younger than the age of sixteen (16). We will delete any Personally Identifiable Information collected that we later determine to be from a user younger than the age of sixteen (16)
Phone: +1 (844) 217–3923
Address: 2900 W. Alameda Avenue, Burbank, CA 91505 Attn: Legal Affairs