Last Updated: December 1, 2023
Changes to this Policy
Conflict Between This Policy and Laws and Regulations
INFORMATION WE COLLECT
We may collect or receive Information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
Personal identifiers and contact information such as name, mailing address, service address, email addresses, and phone numbers;
Sensitive personal identifiers such as gender, age, ethnicity, and country of origin;
Internet and network information such as browsing/search history, IP address, data collected by cookies and similar technologies, device specifications such as device IDs, specifications, and operating system;
Geolocation data such as geographic location indicators from mobile devices, websites, and service addresses;
The types of Personal Information we collect about you may vary based on how you use our Sites or Services, and your relationship with us, and may or may not include some of the categories identified above.
We automatically collect Information related to your actions on our Sites (“Usage Data”). For example, each time you use our Sites, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, your IP address, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If this Information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information cannot be individually associated with you, we treat it as Usage Data.
HOW WE COLLECT INFORMATION
Your Voluntary Disclosure
You may provide us with Personal Information when you communicate with us online or offline, including through our “contact us” page, events, surveys, and marketing or promotional programs. You are not required to provide us with your Personal Information; however, if you choose not to provide the requested Information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction (e.g., we may not receive any information from you on our “contact us” page).
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokers, consumer reporting agencies, marketing agencies and partners, analytics firms, and government agencies.
Cookies and Other Automated Tools
We use the following types of cookies:
Essential Cookies. Essential Cookies are necessary to provide you with services available on our Site. For example, they help to load the content quickly.
Functionality Cookies. Functionality Cookies allow us to remember your choices when using our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies. Analytics and Performance Cookies are used to collect Information about traffic to our Site and how users use our Site. The Information gathered does not directly identify any individual visitor. However, it may render such visitors “indirectly identifiable” because the Information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. Therefore, the Information collected is aggregated and anonymous. We use this Information to help operate our Site more efficiently, gather broad demographic Information, and monitor the activity level on our Site. We also use several third-party tools and services for this purpose.
Targeted and Advertising Cookies. Targeted and Advertising Cookies track your browsing habits to enable us to show third-parties what may be of interest to you. These cookies use Information about your browsing history to group you with other users with similar interests. Based on that Information, a third-party may place cookies to enable them to show adverts that may be relevant to your interests while on a third-party site. Third-party advertisers may also use other technologies in addition to cookies (such as web beacons) to measure their advertisements’ effectiveness and personalize their advertising content.
Log Files. Log File information is automatically reported by your browser when you access a web page. When you use our Site, our servers automatically record certain Information your web browser sends whenever you visit any site. These server logs may include Information such as your web request, IP address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such Information.
We may employ software technology that tracks certain aspects of a user’s visit to our Sites. This technology helps us better manage content on our Sites by informing us what content is effective, how consumers engage with our Sites, and how consumers arrive at and/or depart from our Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code embedded in a web page that track usage activity, including which pages are viewed, when they are viewed, and how long they are viewed. Clear gifs are tiny graphics with unique identifiers embedded in web pages and email messages that track whether a user views a web page or email message. In addition, user activity information may be associated with additional Information about a user’s session and Personal Information, if provided by the user.
How Can I Disable Cookies?
You can typically reset your web browser to refuse all cookies or to notify you when a cookie is being sent. To do this, follow the instructions provided by your browser (usually located within the “settings”, “help” or “tools” function). Unfortunately, many browsers default to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in using our Site, and some features may not function properly.
Visit www.allaboutcookies.org or www.whatarecookies.com for more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them.
Our Site may include social media features, including, but not limited to, the Facebook, YouTube, Pinterest, LinkedIn, Instagram, TikTok, and Twitter widgets or links. These features may collect Information about your IP address and the pages you visit on our Site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
THIRD PARTIES THAT COLLECT INFORMATION ON OUR SITES
Third-parties, including advertisers, collect Personal Information and/or Usage Data from users of our Sites using automatic information collection tools such as cookies and tracking pixels. These third-parties’ data policies govern their data collection, use, and disclosure of Personal Information and/or Usage Data.
HOW WE USE AND SHARE INFORMATION
We use Personal Information for business purposes, such as (i) market research to send communications and offers, including offers based on user interests, personal and business characteristics and location, perform analytics for market and consumer research, trend analysis, financial analysis, and anonymization of personal Information; (ii) other company communications: to provide consumers with Information that may be of interest such as company newsletters, mail and text messaging marketing campaigns, announcements, reminders and service bulletins; (iv) Site use and analytics: to provide you with access to and use of our Site, analyze use of our Site; and (v) and for business operations to evaluate, develop, and improve business operations, products and services offered, perform business administration and other normal business activities.
Reviews and Testimonials
If you provide a review or testimonial, we shall have the right to post it publicly on our Sites or in other advertising material. By providing a testimonial, you permit us to use it in any manner and for any purpose, including in marketing and advertising communications.
We may provide your Personal Information to other businesses (“Service Providers”) to provide services to us or on our behalf. Categories of service providers we use include:
Marketing and communications vendors, which help us market our products/services to you, conduct promotions, surveys and other outreach campaigns;
Research and development vendors, which help us develop and improve our products and services;
Data and business analytics vendors (e.g., Google analytics), which help us collect, analyze and improve the accuracy of our data (including Personal Information);
IT and network administration vendors, which provide services such as data storage and management, website hosting, and data security;
Professional service firms, which provide accounting, legal and other professional services; and
General service providers, which help us with day-to-day business operations such as office support services, courier services, facilities management, and document destruction.
Each Service Provider is expected to use reasonable security measures appropriate to the nature of the Information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information that we provide to them other than as specified by us.
In the past twelve months, we have shared the following categories of Personal Information with at least one Service Provider: personal identifiers and contact information; sensitive personal identifiers; other demographic information; commercial information; internet & network information; geolocation data; audio/visual Information; professional/employment information; education information; and inferences drawn from other Personal Information or data.
Third-Party Selling and Sharing
WE DO NOT SELL PERSONAL INFORMATION TO THIRD PARTIES. WE ALSO DO NOT SHARE ANY PERSONAL INFORMATION WITH THIRD PARTIES FOR THEM TO USE FOR THEIR MARKETING PURPOSES.
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect Information transmitted on or through our Sites or Services, you do so at your own risk.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, at our discretion, we believe it is necessary or appropriate to: respond to legal requests (including court orders, investigative demands, and subpoenas); protect the safety, property, or rights of ourselves, consumers, or any other third party; prevent or stop any illegal, unethical, or legally actionable activity; or comply with laws.
The Sites may contain links to third-party websites including social media platforms. Please be aware that if you access these links, you will leave our Site. We encourage users to read the privacy policies of those sites, as we are not responsible for their content, links, or privacy procedures.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us, including our affiliates and subsidiaries without limitation. In addition, if we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
The Sites and Services are not intended for children under 16, and we do not knowingly collect Personal Information from children under 16. If we become aware that we have inadvertently received Personal Information from a child under 16, we will delete such Information from our records.
Your Rights Related to Your Personal Information
Certain laws and regulations, such as the California Consumer Privacy Act (“CCPA”) and General Data Protection Regulations (EU) 2016/679 (“GDPR”), provide consumers with specific rights related to their Personal Information.
We do not market or intend for our Site to be accessed by California residents or persons residing from outside the United States. However, to the extent that our Site is used by California or non-US residents (or persons of other residences), the following provisions shall apply.
Although we do not offer our products and services in the EU or California, to the extent applicable, you may have the following rights:
Request access to your Personal Information. You may request a copy of the Personal Information we hold about you to check that we are lawfully processing it. You may request confirmation on whether or not we are processing or storing your Personal Information. To the extent applicable to you in accordance with such laws (as applicable), you may also have the rights further described in Article 15 of the GDPR.
Right to Know. Under the CCPA, you may request receipt of certain Information about our collection and use of your Personal Information over the past twelve (12) months. Once we receive your request and confirm your identity, we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling that Personal Information.
The categories of third-parties with whom we share that Personal Information.
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
sales, identifying the Personal Information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
The specific pieces of Personal Information we collected about you.
Request correction of the Personal Information that we hold about you. You may request that we correct any incomplete or inaccurate Information we hold about you. You can review and change your Personal Information by logging into the Platform and visiting your account profile page. You may also email us at [Urbanex email] to request access to, correct, or delete any Personal Information you have provided us. We may not accommodate a request to change Information if we believe the change would violate any law or legal requirement or cause the Information to be incorrect. To the extent applicable, you may also have the rights further described in Article 16 of the GDPR.
Request erasure of your Personal Information. You may request that we delete or remove your Personal Information where there is no proper reason for us continuing to process it. You may also ask us to delete or remove your Personal Information where you have exercised your right to object to processing. To the extent applicable, you may also have the rights further described in Article 17 of the GDPR or the CCPA. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the Information applies, such as those set out in Cal. Civ. Code § 1798.105(c), (d), to the extent applicable.
Object to processing of your Personal Information or request the restriction of processing of your Personal Information. If we are relying on a legitimate interest as the legal basis for our processing and there is something about your situation that makes you want to object to processing of your Personal Information, you may object to such processing. You also may object if we are processing your Personal Information for direct marketing purposes. You may ask us to suspend the processing of your Personal Information, for example, if you want us to establish its accuracy or the reason for processing it. To the extent applicable, you may also have the rights further described in Article 18 or Article 21 of the GDPR.
Request the transfer of your Personal Information. You may request us to provide you, or a third-party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. This right applies to automated Information you initially provided consent for us to use or where we used the Information to perform a contract with you. To the extent applicable, you may also have the rights further described in Article 20 of the GDPR.
Withdraw consent. This right exists where we are relying on consent to process your Personal Information (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Site. We will advise you if this is the case at the time you withdraw your consent. To the extent applicable, you may also have the rights further described in Article 7(3) of the GDPR.
How to Exercise Your Rights
If you want to exercise any of the rights described above, please contact us by email at [email protected] or by mail at Urbanex, 230 Great Circle Rd., Suite 210 Nashville TN 37228.
Only you, or someone legally authorized to act on your behalf, may request to know, access, or delete your Personal Information. We may need specific Information from you to help us confirm your identity and ensure your right to access such Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who does not have the right to receive it.
We will confirm receipt of your request within ten (10) business days. We try to respond to all legitimate requests within one month of our receipt. Occasionally, it may take us longer than one month if your request is complex or you have made a number of requests. In such a case, we will notify you and keep you updated on the status of your request. We retain the right to respond within longer timeframes set forth under applicable law, such as the CCPA.
To the extent a request is made pursuant to the CCPA, any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
For data portability requests, we will select a format to provide your Personal Information that is readily useable and allow you to transmit the Information from one entity to another entity without hindrance. 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. 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.
We will not discriminate against you for exercising your rights under applicable laws such as the GDPR or CCPA. Unless otherwise permitted by applicable law, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you with a different level or quality of goods or services.
Suggest that you receive a different price or rate for goods or services or a different level or quality.
However, we may offer you certain financial incentives permitted by applicable law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires prior opt-in consent, which you may revoke at any time.