Privacy Policy and Your Privacy Rights
Last Updated: August 5, 2024
This Privacy Policy applies to the information Playboy Enterprises, Inc. and its subsidiaries and affiliates (collectively, “PEI,” “we,” or “us,” or “our”) collect through the websites, mobile-optimized websites, mobile applications, electronic devices, kiosks, and all other interactive services we provide at playboy.com, playboytv.com, playboyplus.com, iplayboy.com, and honeybirdette.com and all of the associated content, functionalities, and advertising (collectively, the “Services”). This Privacy Policy governs the Services regardless of how you access them.
For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations. Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to PEI generally or in any specific context.
This Policy expressly incorporates any privacy notices we may issue to supplement this Privacy Policy, for example if required by law. Depending on your residency, a supplemental privacy notice may apply to you. For example, if you are a California resident, please view our California Privacy Policy. Some Services may have a specific, separate privacy policy that will govern use of those Services. In the event of a conflict between the terms of the Privacy Policy and the terms of the privacy governing a specific Service, the terms of the Service’s privacy policy shall govern.
The Privacy Policy describes:
- The personal information we collect and how we collect it.
- What we do with the information we collect.
- How we share and disclose information with third parties.
- Use of online analytics and tailored advertising.
- How you can access and update your information.
- How we protect information.
- How long we retain your information.
- Linked websites and advertisements.
- Use of the Services by users from outside the United States.
- Use of the Services by children prohibited.
- Do-Not-Track disclosure requirements.
- Colorado, Connecticut, Oregon, Texas, Utah, and Virginia Users’ Rights.
- Nevada Users’ Rights
- EU and UK data subject rights.
- No rights of third parties.
- Changes to this Privacy Policy.
You should read this Statement carefully, so that you understand our privacy practices. By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement. If you do not agree to this Statement, you may not use the Services. This Statement applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.
We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Statement supplements these other notices and is not intended to override them. Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use incorporated by reference into this Policy.
If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “How to contact us” section below.
1. The personal information we collect and how we collect it.
Personal information is any information that relates to an identified person or information, which together with other information, may identify a person. How we collect and store information depends on the websites you visit, the activities in which you participate, and the Services you use. You can use some of the Services without providing any information other than what is automatically collected as described in section 1.10. For certain Services, you are required to provide personal information or you will not be able to use the Services. Below we describe the types of personal information that we collect, how that information is used, and the legal basis for the collection of such information.
1.1 Information you provide to use the Services
We collect any information that you provide during your use of the Services, including your first and last name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, and birth year. We also collect information you provide or allow us to access when you do certain things, such as:
- Enter registration information for one or more of our Services;
- Enter a sweepstakes or contest or register for a promotion;
- Participate in voting or polling activities;
- Make a purchase;
- Request certain features (e.g., newsletters, updates, and other products);
- Sign up to receive SMS (text message) notifications;
- Download or use one of our mobile applications; or
- Connect with the Services or otherwise allow us to access certain information about you via a social networking site.
We may collect and store your user ID associated with a social networking service (SNS) account that you use to sign in to your PEI account or connect or use with the Services. When you sign in to your PEI website account or mobile application with your SNS account information or otherwise connect to your SNS account with the Services, you authorize PEI to collect, store, and use in accordance with this Privacy Policy any and all information available to PEI through the SNS interface, including without limitation any information that you have made public in connection with your SNS account, information that the SNS shares with us, or information that is disclosed as being shared during the sign-in process.
You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of the Service because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions through the Services.
1.2 Analytics Information
We collect certain analytics information automatically as you navigate our Services. This includes cookies, tracking pixels, tags or similar tools, which may collect information about your browser, device, geolocation, and interactions with the Services, Site, or emails. For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
1.3 Information you post on or to the Services
We also collect content, such as comments, that you choose to post to or on any of the Services. Other than the information described in section 1.1, posting content to the Services is completely optional and you may still use the Services if you do not choose to post content. Please be careful and responsible whenever you are online. If you use a forum, blog, channel, bulletin board, chat room, user commenting features, or other interactive sharing or social features that may be offered through the Services, any personal information you submit, disclose, or otherwise publish is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties. In addition, such postings may appear on other websites or when searches are performed on the subject of your posting. If you post your email address or other personal information, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information if it has been reproduced on other websites or shared with third parties outside of our control.
1.4 Payment information
If you choose to access our paid Services or to make a purchase, we will collect information such as your credit or debit card information, billing address, shipping address, and transaction history.
1.5 Automatically-collected information
We automatically collect certain information when you use the Services:
- Device information: We collect information about the device that you use to access or use the Services, such as hardware model, operating system, browser information, and IP addresses.
- Mobile device information: In addition to the device information described above, we collect certain information when you access the Services via a mobile device, such as the unique device identifier assigned to your device, operating system, and other device attributes.
- Location information: We collect information about your location, such as general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Los Angeles, the Services may be customized with Los Angeles-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
- Usage information: We collect information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.
As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.
We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique identifier (that is not intended to be used by itself to identify you) for our internal use, in which case your identifier will be considered PEI information and nothing in this Privacy Policy restricts how PEI may use this information.
1.6 Commercial History
This includes information regarding the purchases you have made through our Services and your subscription information. We collect this information for the purposes of account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
1.7 Payment Information
This includes name, address, phone number, and debit or credit card information. We collect this information for the purposes of account creation and management, analytics and research, customer service, and website security and maintenance.
1.8 Responses to Surveys and Questionnaires
This includes any information you provide to us when you voluntary market research surveys such as email address and interested activities. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
1.9 Social Media Information
This includes information that you post by sharing on a blog or another social media platform. We collect this information when you provide it directly to us. Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private. We collect this information for the purposes of advertising and marketing, analytics and research, customer service, and website security and maintenance.
1.10 Cookies and other electronic technologies
We may send one or more Cookies to your computer or other device. We also use other similar technologies such as tracking pixels, tags, web beacons, or similar tools when you visit our Site. We may also use these tools in emails and newsletters to determine when the messages have been opened and for other analytics purposes. These technologies can collect the data described in section 1.5, above. This information allows us to understand how you use the Site and when you interact with our emails.
1.11 Chat Bot Information
Chat Bot Information includes relevant Analytics Information as well as any information that you may submit to us through the use of our chat bot or related customer service tools. Please note that when engaging with our automated tools, you may not be communicating with a live person. Please also note that we may record your communications submitted through the chat bot and disclose such recordings to our service providers, who allow us to provide these tools and functionality. We collect this information to provide customer service, improve our services, and facilitate our communications with you.
The following chart identifies the purposes for which we collect information, the categories of information we may collect, and how we may use and disclose those categories of information.
Purpose | Categories of Personal Information | Targeted Ad / Sales | Data Shared with Third Parties | Categories of Third Parties |
Account Creation and Management | Automatically-collected information Analytics Information Chat Bot Information Cookies and other electronic technologies Information you provide to use the Services Information you post on or to the Services Social Media Information Responses to Surveys and Questionnaires | Yes / No | Analytics Information | Analytics Providers Third Party Advertisers |
Purchase of Goods or Services | Analytics Information Commercial History Cookies and other electronic technologies Information you provide to use the Services Payment Information | Yes / No | Analytics Information Commercial History Contact Information | Analytics Providers Third Party Advertisers |
Marketing and Advertising | Analytics Information Automatically-collected information Commercial History Cookies and other electronic technologies Information you provide to use the Services Information you post on or to the Services Responses to Surveys and Questionnaires Social Media Information | Yes / No | Analytics Information Commercial History Contact Information | Analytics Providers Third Party Advertisers |
Analytics and Research | Analytics Information Automatically-collected information Chat Bot Information Commercial History Cookies and other electronic technologies Information you provide to use the Services Information you post on or to the Services Responses to Surveys and Questionnaires Social Media Information | Yes / No | Analytics Information Commercial History Contact Information Social Media Information | Analytics Providers Third Party Advertisers |
Customer Service | Analytics Information Automatically-collected information Chat Bot Information Information you provide to use the Services Information you post on or to the Services Responses to Surveys and Questionnaires | Yes / No | Analytics Information | Analytics Providers Third Party Advertisers |
Website Security and Maintenance | Analytics Information Automatically-collected information Chat Bot Information Commercial History Cookies and other electronic technologies Information you provide to use the Services Responses to Surveys and Questionnaires | No / No | N/A | N/A |
What Are Cookies?
Cookies are small files created by websites, including our Site, that reside on your computer’s hard drive and that store information about your use of a particular website. When you access our Site, we use Cookies and other tracking technologies to:
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize our Site according to your individual needs;
- Contact you to provide you with information or services that you request from us;
- Advertise new content, events, and services that relate to your interests;
- Provide you with more personalized content that is most relevant to your interest areas; and
- Recognize when you return to our Site.
We set some Cookies ourselves and others are set by third parties. You can manage your Cookies preference as described in the “Managing Your Cookies” section below.
What Types of Cookies Do We Use and Why?
The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers. Because the specific cookies we use may vary over time, as well as differ by the specific page you are browsing, the below chart is illustrative only.
Types of Cookies | Purpose | Who Serves (for example) |
Essential | These cookies are required for the operation of the Services and enable you to move around the Services and use its features. Disabling these cookies can negatively impact the performance of Services. | |
Functionality | These cookies are used to recognize you when you return to the Services. This enables us to personalize content for you and remember your preferences. These cookies also enable your interactions with the Services such as emailing us and customer support chat. | |
Analytics, Performance, and Research | These cookies, beacons, and pixels allow us to analyze activities on the Services. They can be used to improve the functioning of the Services. For example, these cookies recognize and count the number of visitors and see how they move around the Services. Analytics cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Services for those who engage with our advertising. | GoogleIGoDigitalMetaTikTokAnalyticsLive Intent |
Social Networking | These cookies are used to enable you to share pages and content that you find interesting on our Services through third-party social networking and other websites. These cookies may also be used for advertising purposes. | |
Advertising | These cookies and pixels are used to deliver relevant ads, track ad campaign performance, or track email marketing. | GoogleSnapchat For BusinessDoubleclickTradeDeskQuantCastAttn.tv |
We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.
How Long Do Cookies Stay on My Device?
Some Cookies operate from the time you visit the Site until the end of that particular browsing session. These Cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.
Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These Cookies are called “persistent cookies” and the length of time they will remain on your device will vary from Cookie to Cookie. Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Site, how your use of the Site may change over time, and the effectiveness of advertising efforts.
Managing Your Cookies
It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies), you may not be able to access all or parts of the Site. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. You have the right to opt out of non-essential cookies, such as for analytics or advertising purposes, at any time. You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.
Does the Site Respond to “Do Not Track” Signals?
There is currently no industry agreed-upon response to a Do Not Track signal. At this time, our Site does not respond differently based on a user’s Do Not Track signal. We respond to the Global Privacy Control. Your browser must be able to support the Global Privacy Control for us to recognize your opt-out preference signal.
1.11 Information from third parties
We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.
1.12 Aggregate or de-identified data
We may aggregate and/or de-identify information collected by the Services or via other means so that the information cannot reasonably be used to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.
1.13 Emails
You must provide your email when you signup to be a PCBI member. We use your email to provide you with service related materials and correspondence. You may also opt-in to receiving promotional materials via email. Both members and non-members that have provided their email addresses may opt out of receiving promotional emails at any time.
2. What we do with the information we collect.
We use the information we collect to provide our services to you, to improve our services and site, and to protect our legal rights. We do not store, access, transmit, retain, or otherwise use personal information in any way that is incompatible with this Privacy Policy without your consent. Specifically, we may use the information we collect to:
- Provide you with services you request;
- Communicate with you about our site or services or to inform you of any changes to our site or services;
- Identify new opportunities or services that may be of interest to you; Provide support
- Maintain and improve our site and services;
- Defend our rights and the rights of others;
- Efficiently maintain our business; and
- Comply with applicable law.
The Services are supported in part by advertising revenue. We may send you commercial emails on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you will have an opt-out that you can use to stop receiving such communications. It may take up to seven days for us to process an opt-out request. We may continue to send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving such emails. Please note that opting out of receiving promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
3. How we share and disclose information with third parties.
We may share personal information with the following categories of third parties:
- Our service providers;
- Our affiliates;
- Other non-affiliated third parties on the basis of your consent or the legitimate interest of providing you with products or services that may be of interest to you; and
- Government and regulatory agencies when required by law or in response to lawful requests from third law enforcement.
We may also share the information we collect in the event of a merger, acquisition, or sale of our business, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety, protect the safety of others, or prevent or investigate fraud. We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose. If you have any questions about how we share your personal information, please contact us via the methods identified in How to Contact Us section below.
4. Use of online analytics and tailored advertising.
4.1 Online analytics
We may use third-party web analytics services on our Services, such as those of Google Analytics. These service providers use the sort of technology described in Section 1.5 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. You may opt out from the use of cookies and other technology for analytics at any time. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
4.2 Tailored advertising
When you use the Service, PEI may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests. You have the right to opt out of cookies and other technologies that provide you with such tailored advertising, as described in Section 1.5.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiatives Consumer Opt-Out link, the Digital Advertising Alliances Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use any links that may be available in advertisements that appear in the Services to learn more.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored specifically to you. We do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. When using a mobile application you may also receive tailored in-application advertisements. Each operating system (iOS for Apple phones, Android for Android devices and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.
5. How you can access and update your information.
To ensure that you have some control over the information we have about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (may be available on some Services and not others) or by contacting us at [email protected].
6. How we protect information.
We have implemented a variety of administrative, technical, and physical security measures to protect against the unauthorized access, destruction or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.
7. How long we retain your information.
We will retain your information for as long as you use the Services and for a limited period after you stop using the Services for billing and collection purposes.
8. Linked websites and advertisements.
The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites. We have relationships with third-party providers to provide content, products, services, and functionality through the Services. When you visit websites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the website or Services in connection with such content, products, services, or functionalities, we share any information you provide or that is collected during your use of those Services with those providers as set forth in Section 3. In some cases, the provider may collect information from you directly, in which case the provider’s privacy policy (which may differ from this Privacy Policy) would apply. If you have any questions regarding the privacy policy of any of our providers, you should contact the provider directly for more information.
9. Use of the Services by users from outside the United States.
Personal Data captured on this website may be transferred to, and stored or otherwise processed at, a destination outside the European Economic Area (hereinafter “EEA”), including destinations that are not subject to Data Privacy Provisions equivalent to those in the EEA countries in which you provided your Personal Data. We transfer your data to the US with your consent or where necessary to provide you with the services you have requested. We will take all steps reasonably necessary to ensure that your Personal Data is processed safely and in accordance with this Privacy Policy.
10. Use of the Services by children prohibited.
The Services are not intended for persons under the age of 18. By using the Services, you hereby represent that you are at least 18 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories shall have no bearing on this limitation.
If you become aware that your child has provided us with personal information, please contact us at [email protected]. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we take steps to remove such information and terminate the child’s account.
11. Do-Not-Track disclosure requirements.
We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiatives Consumer Opt-out link, Digital Advertising Alliances Consumer Opt-Out Link, TRUSTe’s Advertising Choices page, and the Google opt-out link set forth in sections 4.1 and 4.2. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the US Internet industry is currently still working on Do Not Track standards, implementations and solutions.
12. Colorado, Connecticut, Oregon, Texas, Utah, and Virginia Users’ Rights
Colorado, Connecticut, Oregon, Texas, Utah, and Virginia residents have certain rights with respect to their data. These rights are established through the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Oregon Consumer Data Privacy Act (“OCDPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). The chart below explains these rights and lists the states whose residents may exercise those rights. To exercise any of the rights listed in the chart below, please email us using the information set forth in the “How to contact us” section below.
Consumer Right | Explanation |
Right to Know/Access | You have the right to confirm whether we are processing your personal data, and the right to access that data. Residents of Oregon may request a list of the third parties, other than natural persons, to whom we have disclosed your personal information. |
Right of Correction | You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data. *Not available under Utah Law. |
Right of Deletion | You have the right to delete your personal data provided by you or obtained about you. *In Utah, this right is limited to only that information you have provided directly to us. |
Right of Portability | Up to two times per calendar year, you have the right to obtain your personal data in a portable and—to the extent technically feasible—readily usable format that allows you to transmit the data to another entity without hindrance. |
Right to Opt-out: | You have the right to opt-out of the processing of your personal data for the purposes of: Targeted advertising; The sale of personal data; and/or Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. *Right to opt-out of profiling not available in Utah. To opt-out, please visit our “Do Not Sell or Share My Personal Information” page. |
Our use of online analytics and advertising cookies may constitute the sale of information or use of information for targeted advertising purposes under certain laws. Therefore, we allow you to opt-out of our use of cookies and related technologies through our cookie banner and through the link provided above.
12.1 Sensitive Information
Sensitive Data as defined under Colorado, Connecticut, Texas, Utah, and Virginia law includes precise geolocation information. For the purposes of serving you relevant advertisements based on your location, we collect geolocation information to perform geofencing. We will not collect this information from Colorado, Connecticut, Texas Utah, and Virginia residents without first obtaining consent.
12.2 Exercising Your Rights
If you are a Colorado, Connecticut, Oregon, Texas, Utah, or Virginia resident and wish to exercise one of the above rights and it applies to you, you may submit a request by clicking here and/or visiting our “Do Not Sell or Share My Personal Information” page.
If necessary, we may request additional information reasonably necessary to authenticate you and your request. We reserve the right to refuse or limit requests where permitted by applicable law.
In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights.
We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay. If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.
We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside. We may charge a fee in:
- Colorado, Connecticut, Oregon and Utah if you make more than one request in a twelve-month period; and
- Connecticut, Texas, and Virginia, if the request is manifestly unfounded or excessive, or repetitive in nature.
12.3 Appealing a Rights Request Decision
If you are a resident of Colorado, Connecticut, Oregon, Texas, Utah, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision. To do this, you may email us at [email protected]. In the email appeal, please specify the right(s) you requested to exercise and the date you made such a request.
We will inform you in writing within 45 days of any action taken or not taken in response to the appeal. We will also provide a written explanation of the reasons for our decisions regarding your request(s).
13. Nevada Users’ Rights
Under Nevada law, certain Nevada consumers may opt out of the sale of certain personally identifiable information for monetary consideration to a person for that person to license or sell such information to additional persons. We do not sell personally identifiable information under Nevada law.
If you are a Nevada resident who has purchased or leased goods or services from us, you may (A) submit a request to opt out of any potential future sales, and/or (B) request changes to your Covered Information by emailing us at [email protected]. Please note we will take reasonable steps to verify your identity and the authenticity of the request.
14. EU, UK and Swiss data subject rights.
Under the European Union (EU) and United Kingdom (UK) General Data Protection Regulations (GDPR) and the Swiss Revised Federal Data Protection Act (FADP), you may have the following rights:
- Right of access: You have the right to request a copy of the information that we hold about you.
- Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected. Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.
- Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information. Right to withdraw consent: If you have provided consent for the processing of your information you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
- Right of portability: In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.
- Right to object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).
- Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling.
- Right to lodge a complaint: You have the right to lodge a complaint with your relevant Data Protection Authority if you believe that we have not complied with the requirements of the GDPR with regard to your personal information.
14.1 Legal basis for processing
Residents of the EU, UK, or Switzerland may be entitled to an explanation of the legal basis on which we rely to process your personal information. We process your personal information on the basis of:
Consent: We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
Our Legitimate Interests: We may process your personal information if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. We may process your information on the basis of our legitimate interest when managing your account and providing you services, providing you with notices and communications, administering sweepstakes, and performing analytics to improve our services. There may be other circumstances in which our legitimate interest is a secondary grounds for processing your information.
To Perform a Contract: We may process your personal information to administer and fulfill contractual obligations to you.
To Enable Us to Comply with a Legal Obligation: We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
Necessary for the Exercise or Defense of Legal Claims: If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim. If you wish to assert any of your rights or if you have questions about our legal basis for processing, please contact us in accordance with the How to Contact Us section, below.
15. No rights of third parties.
This Privacy Policy does not create rights enforceable by third parties.
16. Changes to this Privacy Policy.
PEI reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.
17. How to contact us.
If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to [email protected].