PRIVACY POLICY
Effective Date: October 1, 2020.
Introduction and Overview.
This Privacy Policy describes how Gurls Talk, Inc. (“Gurls Talk,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices about such use and sharing. It applies to any online location that posts a link to this Privacy Policy (collectively, the “Service”). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection).
By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.
If you have any questions about our privacy practices, please contact us as set forth in the section entitled “Contact Us” below. If you are a Nevada resident, California resident, or data subject in Europe, please see the additional disclosures at the end of this Privacy Policy.
Information Collection.
We collect information you provide directly via the Service, such as when you make a donation access our content, submit your original content, participate in a sweepstakes, contest, survey, or other promotion (“Promotion”), comment on our content, contact customer support, or apply for our ambassador program. We may use Service Providers (defined below) to collect this information.
The categories of information we collect include the following:
Contact Data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data, including without limitation social media addresses, handles, and avatars.
Credentials. We collect usernames, passwords, password hints, and similar security information for authentication and account access.
Demographic Data. We collect demographic information such as your country.
Payment Data. We collect data necessary to process your payment if you make a purchase, such as your payment
instrument number (such as a credit card number), and the security code associated with your payment instrument.
Profile Data. We collect your interests, favorites, and other profile data.
Content. We collect the content of messages you send to us, such as feedback and article reviews you write, or questions and information you provide to customer support. We also collect the content of your communications as necessary to provide you with the services you use or if you publicly post on the Service. For example, if you comment on an article through the Service, we need to collect the content of that comment to display it in the comments section of the that article on the Service.
Ambassador Program Application Data. We collect information when you apply to be part of the Gurls Talk Ambassador Program. We collect your Contact Data, additional information about you that you provide, and your answers to any prompts set out in the application (such as your suggestions to improve the Gurls Talk impact on gxrls’ mental health). Please refrain from sharing any sensitive information such as your own mental health condition as part of the application process.
You may choose to voluntarily submit other information to us through the Service that we do not request, and, in such instances, you are solely responsible for such information.
Information Collected Automatically.
We automatically collect information when you use our Service. The categories of information we collect include the following:
Service Use Data. We collect data about the features you use, the pages you visit, the e-mails and advertisements you view the time of day you browse, your referring and exiting pages, and other similar information.
Device Connectivity and Configuration Data. We collect data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and other similar information. This data also includes IP address, MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers.
Location Data. We collect imprecise location data imprecise (e.g., location derived from an IP address or data that indicates a city or postal code level).
We use various tracking technologies to collect this information (“Tracking Technologies”), including the following:
Cookies. Cookies are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising off the Service. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
Log Files. A log file is a file that records events that occur in connection with your use of the Service, such as your service use data.
Pixels. A pixel (also known as a web beacon) is code embedded in a website, video, e-mail, or advertisements that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, e-mail, or advertisement that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from third parties that allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
Some information about your use of the Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use with you, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.
For further information on Tracking Technologies and your rights and choices regarding them, see the sections entitled “Third Parties” and “Your Rights and Choices” below.
Information from Other Sources.
We also obtain information about you from other third party sources. We protect data obtained from these third parties according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These third party sources include:
Data brokers from which we purchase data to supplement the data we collect.
Social networks when you reference our Service or grant permission to Gurls Talk to access your data on one or more of these services.
Partners with which we offer co-branded services, sell, or distribute our products, or engage in joint marketing activities.
Publicly-available sources such as open government databases or other data in the public domain.
For further information on Third Party Services, see the section entitled “Third Parties” below.
Use of Information.
We use information about you for our legitimate interests, including to:
Manage and operate our Service, including to facilitate donations.
Perform services requested by you, such as to respond to your comments, questions, and requests, and provide customer service.
Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
Prevent and address fraud, breach of policies or terms, and threats or harm.
Monitor and analyze trends, usage, and activities.
Conduct research, including focus groups and surveys.
Improve the Service or other Gurls Talk websites, apps, marketing efforts, products and services.
We also use information about you with your consent, including to:
Verify your eligibility and deliver prizes in connection with Promotions you have entered.
Post your Submissions to the Gurls Talk website.
Send you communications regarding our and third party products, offers, promotions, rewards, events, and services that may be of interest to you.
Develop and display content, and features on our Service as well as on other platforms and services.
Fulfill any other purpose at your direction or with notice to you and your consent.
Notwithstanding the above, ewe may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use your information, please see the section entitled “Your Rights and Choices” below.
Sharing of Information.
We share information we collect in accordance with the practices described in this Privacy Policy. We share information about you as follows:
Service Providers. We share your information with our agents, vendors, and other service providers (collectively “Service Providers”) in connection with their work on our behalf. Service Providers assist us with services such as payment processing for Gurls Talk donations, data analytics, marketing and promotional services, Promotions, website hosting, and technical support. Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for any other purpose except as prohibited by applicable law.
Affiliates. We share your information with our related entities including our parent and sister companies. For example, we may share your information with our affiliates for customer support, fundraising, marketing, and technical operations.
Business Partners. We share your information with our business partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing or fundraising activities.
Promotions. Our Promotions may be jointly sponsored or offered by third parties. If you voluntarily choose to enter a Promotion, we share your information as set forth in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
Third Parties. We share your information with third parties for purposes of facilitating your requests (such as when you choose to share information with a social network about your activities on the Service) and in connection with tailoring advertisements, measuring and improving our Service and advertising effectiveness, and enabling other enhancements.
Merger or Acquisition. We share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
Security and Compelled Disclosure. We share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share your information to protect the rights, property, life, health, security and safety of us, the Service or any third party.
Consent. We share your information for any other purpose disclosed to you and with your consent.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we share your information, please see the section entitled “Your Rights and Choices” below.
Public Information.
Certain areas of the Service, such as the comments section of certain articles on the Services or your own submissions on the Service, are designed to help you share information with the world. If you make information public through our Service, other people will have access to it. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information; however, California residents and European data subjects have additional rights as set forth below. Your sharing of such public information is also subject to our Terms of Use.
Third Parties.
Third Party Services.
Our Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). These Third Party Services may use Tracking Technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through our Service, a Third Party Service, a Third Party Feature (defined below), or a third party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
Third Party Features.
We may allow you to connect our Service to a Third Party Service or offer our Service through a Third Party Service (“Third Party Features”). If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature, and you should carefully review the third party’s privacy policy and terms of use. Some examples of Third Party Features include the following:
Liking, Sharing, and Logging-In. We may embed a pixel or SDK (e.g., Facebook SDK) on our Service that allows you to “like” or “share” content on, or log-in to make comments on Gurls Talk content through, Third Party Services, including social networks such as Facebook and Twitter. If you choose to engage with such a Third Party Service through our Service, we collect information you have authorized the Third Party Service to share with us (such as your user ID and profile picture). Likewise, if you choose to engage with such a Third Party Service through our Service or visit our Service while logged in to that Third Party Service on your device, the Third Party Service may receive information about your activities on our Service and be able to associate that information with information the Third Party Service already has about you.
Brand Pages. We may offer our content on social networks such as a Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on a Third Party Service (e.g., by using a hashtag associated with Gurls Talk in a tweet or post), we may use your reference on or in connection with our Service.
Analytics and Interest-Based Advertising.
Our Service contains Tracking Technologies owned and operated by Third Parties. For example, we use Tracking Technologies from third party analytics providers, such as Google Analytics, to help us analyze users use of the Service, compile statistic reports on the Service’s activity, and provide us with other services relating to Service activity and internet usage. We also work with ad serving services, advertisers, and other third parties to serve advertisements off the Service and/or on Third Party Services. These third parties may use Tracking Technologies on our Service and Third Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you off the Service and/or on Third Party Services or third party devices after you have left the Service (“Interest-based Advertising”).
For further information on Tracking Technologies and your rights and choices regarding them, please see the sections entitled “Information Collected Automatically” above and “Your Rights and Choices” below.
Your Rights and Choices.
Tracking Technology Choices.
Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
Analytics and Interest-Based Advertising.
You can opt-out of your data being used by Google Analytics through cookies by visiting https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.
The companies we work with to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, http://www.aboutads.info/choices; and (ii) for mobile app opt-out, http://www.aboutads.info/appchoices. In addition, these companies are members of the Network Advertising Initiative (“NAI“). To learn more about the NAI and your opt-out options for their members, please visit http://www.networkadvertising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).
Communications.
E-mails. You can opt-out of receiving promotional e-mails from us at any time by following the instructions as provided in e-mails to click on the unsubscribe link, or e-mailing us at the e-mail address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt-out of non-promotional e-mails, such as those about your submissions, transactions, servicing, or Gurls Talk’s ongoing business relations.
Please note that your opt-out is limited to the e-mail address used and will not affect subsequent subscriptions.
Privacy Rights for Nevada Residents.
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at info@gurlstalk.com.
Privacy Rights for California Residents.
California’s “Shine the Light” law permits customers in California to request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information.
If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Gurls Talk is not required to respond to requests made by means other than through the provided e-mail address or mail address.
Any California residents under the age of eighteen (18) who have registered to use the Service and posted content or information on the Service, can request that such information be removed from the Service by sending an e-mail to the e-mail address set forth in the section entitled “Contact Us” below. Requests must state that the user personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Privacy Rights for Data Subjects in Europe.
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Gurls Talk acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, contact us as set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, please contact us at privacy@gurlstalk.com. You also have the right to lodge a complaint with an EEA supervisory authority in your jurisdiction.
Children.
The Service is intended for a general audience and not directed to children under thirteen (13) years of age. Gurls Talk does not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe Gurls Talk has collected such information in a manner not permitted by COPPA, please contact us as set forth in the section entitled “Contact Us” below, and we will remove such data to the extent required by COPPA.
Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.
International Transfer.
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information in the U.S. and other jurisdictions as set forth in this Privacy Policy. For personal data transferred from Europe, we will provide appropriate safeguards, such as through use of standard contractual clauses.
Changes to this Privacy Policy.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your e-mail address.
Contact Us.
If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:
Gurls Talk, Inc.
333 Schermerhorn Street
Unit 16S
Brooklyn, NY 11217
Phone: +1 (718) 522-3523
Email: info@gurlstalk.com