Privacy Policy - SARA Agency

Privacy Policy

SARA AGENCY PRIVACY POLICY

 

Last Modified: March 13, 2019

 

Green Acres Strategies, LLC – a California limited liability company d.b.a. SARA Agency - (“SARA,” "we" or "us") values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about users of our website, software as a service and the services provided in connection therewith (collectively, the “Services”).

 

By using our Services, or otherwise providing information to us, you agree that your personal information (“Personal Information”) will be handled as described in this Policy. You also agree to the terms for accessing and correcting data as described in this Policy.  Your use of our Services, and any dispute over privacy, is subject to this Policy and our https://sara.agency/terms-and-conditions/ Terms of Use[PDE1] , including its applicable limitations on damages and the resolution of disputes.  The SARA Terms of Use are incorporated by reference into this Policy.

 

The Information We Collect

How We Use the Information We Collect

How We Share the Information We Collect

Our Use of Cookies and Other Tracking Mechanisms 

Cross Border Transfers - GDPR

Communications and Marketing

Mobile Applications

Third-Party Links and Services

Security

How to Access, Correct, Amend, or Delete Your Information

Retention and Deletion

Children's Privacy

Changes to this Policy

Contact Information

THE INFORMATION WE COLLECT

Information We Collect Directly From You. We collect information from you, including Personal Information, when you register to use our Services or otherwise contact us. To register, you may be asked to provide us with certain information such as your name and contact information.  In addition, we collect information from you when you submit electronic data or information to the Services, including any information, data and attachments that you upload or submit; we do not sell, rent or trade this information with third parties.

 

Information We Collect Automatically. We automatically collect information about your use of our Services through cookies, web beacons and other technologies: your domain name; your browser type; your operating system; web pages you view; links you click; your IP address; the length of time you use our Services; your activities on our Services (including your movement through our Services); language information; device identifier; location information; and the referring URL, or the webpage that led you to our Services. Please see the section Our Use of Cookies and Other Tracking Mechanisms below for more information. 

 

We may use the information we collect from you in aggregated form or we may associate it with other Personal Information that we collect about you. We may also combine information collected about you within this Services with information collected through our websites. We explain how we use and disclose the information we collect about you below.

 

Geo-location Information. If you are accessing a Service from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.

 

Information Collected By and From Social Media Services and Other Third Party Platforms. You also can engage with our content, such as video, games, applications, and other offerings, on or through social media services or other third party platforms, such as Instagram® or other third-party social media plug-ins, integrations and applications. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Information in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, like photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or "likes." For a description on how social media services and other third party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings (such as Instagram).  When we interact with you through our content on third party websites, applications, integrations or platforms, we may obtain any information regarding your interaction with that content, such as content you have viewed, your game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on.

HOW WE USE THE INFORMATION WE COLLECT

We may access your account information and other information you submit to us in order to provide our services and otherwise support our business functions.  For example, we may use the information that we gather about you for the following purposes:

 

  • To provide our Services to you, to respond to your inquiries, to provide the information that you requested, and for customer service purposes.
  • To tailor the content and information that we may send or display to you, offer personalized help and instructions, and to otherwise personalize your experiences while using the Services.
  • For marketing and promotional purposes. For example, as permitted under applicable law, we may contact customers and user with newsletters, special offers, and promotions, or otherwise to inform you about products or information we think may interest you.
  • To assist us in advertising our products and services and to inform you about SARA and third-party products and services that may be relevant to you. 
  • For research and analytical purposes, including creating and offering products or services and to better understand how users access and use our Services, both on an aggregated and individualized basis; to administer, monitor, and improve our Services; and for our internal purposes. 
  • To protect our customers, employees or property, including to investigate fraud, harassment or other types of unlawful activities involving SARA, to enforce this Policy, as well as our Terms of Use, as well as evidence in litigation in which we are involved.

 

Some products, services and information we offer may only be suitable for/accessible to individuals meeting certain eligibility or other criteria. In such cases, we may verify that you meet such criteria.

 

We may also may use the information we collect from various customers and sources (including account and transaction data) to create or compile aggregate reports, statistics and other information, that do not identify a particular customer or individual.  This aggregate information may be used by us and third parties to develop, improve, promote or offer products or services, and for other research, development, advertising, marketing or analytical purposes. 

HOW WE SHARE THE INFORMATION WE COLLECT

You can decide what other SARA users will be able to view and respond to your transaction via the Services.  We will not sell, rent or trade the identifiable information we collect or receive from you to third parties, nor will we share it with unaffiliated third parties for their own marketing or business use.  We may disclose the information that we collect about users, including Personal Information and company-specific information (collectively, “information”), as follows: 

 

  • Affiliates. We may disclose the information we collect from users to our affiliates or subsidiaries; however, if we do so, their use and disclosure of information will be subject to this Policy.

 

o   Service Providers. We disclose the information we collect from you to third-party vendors, service providers, contractors, or agents who perform functions on our behalf, such as sending e-mail messages on our behalf or hosting and operating a particular feature or functionality of our Services. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your information for purposes unrelated to the product or service they're providing. We require such third parties to maintain the confidentiality of the information we provide to them. 

 

  • Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company. 

 

  • In Response to Legal Process. We reserve the right to disclose your Personal Information as required by law, when we believe disclosure is necessary to comply with a regulatory requirement, judicial proceeding, court order, subpoena, or legal process served on us, or to protect the safety, rights, or property of our customers, the public or us    

 

  • To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved. 

 

Aggregate and De-Identified Information. We may disclose aggregated and de-identified data that we may create or compile from various sources, including but not limited to the accounts and transactions of multiple users.  This information does not identify individual accounts, companies or company-specific data

 

We may also share your information for other purposes, provided you have granted us consent to do so.

OUR USE OF COOKIES AND OTHER TRACKING MECHANISMS

When you interact with our Services, we strive to make your experience easy and meaningful.  We or our third-party service providers may use cookies, web beacons (clear GIFs, web bugs), and similar technologies to track user activity and collect site data. We may combine this data with the Personal Information we have collected from you. By continuing to use our Services, you are agreeing to our use of cookies and web beacons on your device.

 

Cookies. We and our third-party service providers use cookies to track visitor activity on our Services and to administer the Services. Cookies are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identifies your browser or device. We may use technologies like cookies, pixels and local storage to deliver, secure, and understand products, services, and ads. Our cookies assign a random, unique number to each visitor’s computing device but they do not contain information that would personally identify the visitor, although we can associate a cookie with any identifying information that is or has been provided to us while using our Services. Most browsers allow users to refuse cookies, but doing so could impede the functionality of some portions of our Services.  The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

 

Local Storage Objects. We may also use local browser storage, such as HTML5 Local Storage, to store your preferences and to personalize your visit.

 

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We and our third party service providers may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of visitors, help us manage content and compile statistics about usage.  We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

 

Analytics. We may use automated devices and applications, including those provided by third parties, to evaluate usage of our Services. We also may use other analytic means to evaluate usage of our Services. We use these tools to help us improve our Services, performance and user experiences.

 

Helpful Links.          Advertisers provide information for users to influence how information about their online activities over time and across third-party websites or online services is collected and used.   

·      The Network Advertising Initiative - http://www.networkadvertising.org/managing/opt_out.asp

·      The Digital Advertising Alliance - http://www.aboutads.info/

·      The European Digital Advertising Alliance http://youronlinechoices.eu/.

Cross Border Transfers - GDPR

SARA is a global corporation and we share information globally, both internally and externally with our partners and with those you connect and share with around the world in accordance with this Policy. Your Personal Information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this Policy.  SARA has operations in a number of countries and has developed global data security practices designed to ensure that your Personal Information is appropriately protected.

SARA has implemented appropriate safeguards for transfers of Personal Information originating from the European Economic Area (“EEA”) to SARA, its affiliates and unaffiliated third parties located outside the EEA, and adheres to the General Data Protection Regulation (GDPR) adopted by the European Union.  Where applicable, we adhere to the standard contractual clauses of the GDPR (“Standard Contractual Clauses”), monitor and refer to the European Commission's adequacy decisions about certain countries and obtain your consent for these data transfers to the United States and other countries. In the event you are located in the EEA, Switzerland or the United Kingdom and have not been asked to consent (and have not consented) to the collection of your Personal Information by SARA, its websites and/or the Services for the purposes for collecting and processing the data, please contact us immediately using our Contact Information below.

 

To the extent any information or data you provide to us includes Personal Information of individuals (other than you) located in the EEA, Switzerland and the United Kingdom, and you are deemed a ‘controller’ under the terms of the GDPR, the terms of the Standard Contractual Clauses are hereby incorporated by reference and shall apply to all such Personal Information derived from the EEA, Switzerland and the United Kingdom. For the purposes of the Standard Contractual Clauses set out in the GDPR: (a) you are the data exporter and you consent to the Standard Contractual Clauses and appendices; and (b) SARA is the data importer under the Standard Contractual Clauses and appendices. To the extent that it is determined by any data protection authority that this Policy is insufficient to comply with the applicable data protection laws or to the extent required otherwise by any changes in the applicable data protection laws, you agree to cooperate with us in good faith to comply with any data protection laws applicable to the Services and your use of them.

COMMUNICATIONS AND MARKETING

SARA hopes to deliver to you advertising for products and services you need or want. There are many ways to do this in the online advertising world. For example, we may partner with websites with whom you have shared your interests, conditions and concerns directly and asks that they serve our ads to users who have expressed an interest in our Services or those of the services we integrate with. We may also partner with advertising companies to serve you ads based on your web browsing activity, purchases and/or interests. Some techniques for delivering content based on your interests are referred to as online behavioral advertising.

 

We may display banner ads within our Services.  We may also send alerts and notifications, as well as periodic promotional informational or other marketing emails to you. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending an email to success@sara.agency.  Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving marketing emails, we may still send you alerts, notifications and other e-mails about your account or any services you have requested or received from us.

 

Mobile ApplicationS

 

Our mobile applications may send push notifications directly to your mobile device for the purposes specified in this Policy. You may opt-out of receiving such push notifications and location-based services on your mobile device at any time by editing the notification and location settings on your mobile device.

 

Geo-location Information. If you are accessing a Service from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.

THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites and services. Any access to and use of such linked websites or services are not governed by this Policy, but instead are governed by the privacy policies of those third party websites (such as Instagram). We recommend that you review the privacy statements posted to those websites and services.  We are not responsible for the information practices of such third party websites or services, nor are we responsible for or guarantee the products and services offered by them.  

SECURITY

We have implemented security safeguards (e.g. where appropriate, authentication procedures, password requirements, firewalls, Secure Sockets Layer (SSL) technology, Extended Validation (EV) certificate technology, data encryption, audit logs, backup procedures, intrusion monitoring, usage monitoring and secure facility) to prevent unauthorized access, maintain data accuracy, and ensure the correct use of the information we collect through our Services. Despite our best efforts, no data security measures can guarantee 100% security. 

 

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.  If applicable always comply with your employer’s internal security protocols; including but not limited to using approved computers, devices and networks.

 

Any information you provide us through use of the SARA website may be stored and processed, transferred between and accessed from the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside. However, we will handle your Personal Information in accordance with this Policy regardless of where your Personal Information is stored/accessed.

 

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us by contacting us at success@sara.agency.       

HOW TO ACCESS, CORRECT, AMEND, OR DELETE YOUR INFORMATION 

To correct, amend, or delete your account information (for example, your name, address, or phone number) you may log into your account and update this information.

 

You may also request to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through our website or Services, or object to the use or processing of such Personal Information by us. You have the ability to update certain elements of your profile and related Personal Information at any time by emailing your requests to success@sara.agency or by doing so on your account page.  You may always ask that all of your Personal Information be removed entirely from our systems and your account closed by notifying us at success@sara.agency  If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us through our inquiry form, or write to us at the following address:

Chief Privacy Officer

SARA Agency

506 S Spring St #13308

Los Angeles, CA 90013

USA

 

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed OR REMOVED ENTIRELY from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.

While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within ten (10) days.

Retention and Deletion

We will retain your Personal Information for as long as your account is active; as needed to provide you products or services; as needed for the purposes outlined in this Policy or at the time of collection; as necessary to comply with our legal obligations (e.g., to honor opt-outs), resolve disputes, and enforce our agreements; or to the extent permitted by law.  At the end of the retention period, we will delete your Personal Information in a manner designed to ensure that it cannot be reconstructed or read.

You may always ask that all of your Personal Information be removed entirely from our systems and your account closed by notifying us at success@sara.agency 

Children's Privacy

We are committed to protecting the privacy of children. We do not knowingly collect Personal Information from children under the age of thirteen (13).

CHANGES TO THIS POLICY

From time to time, we may update and timely post revisions to this Policy. Any changes will be effective immediately upon the posting of the revised Policy. If the Policy changes in a way that significantly affects how we handle Personal Information, we will not use the Personal Information we previously gathered in the manner described in the new policy without providing notice and/or obtaining your consent, as appropriate. Minor changes to the policy may occur that will not significantly affect our use of Personal Information without notice or consent. We encourage you to periodically review this page for the latest information on our privacy practices. This Policy was updated as of the effective date listed above. All information submitted through the Services to SARA is subject to the terms and conditions of this Policy, as amended.

CONTACT INFORMATION

If you have any questions, or if you believe there has been a violation of this Policy, the GDPR or any other applicable law that you are aware of, you may contact us at success@sara.agency, or write to us at the following address:

Chief Privacy Officer

SARA Agency

506 S Spring St #13308

Los Angeles, CA 90013

USA