Our website address is: https://sparklingkey.com.
EFFECTIVE DATE: Feb 1, 2019
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WHAT INFORMATION DO WE COLLECT?
Personally Identifiable Information (PII): You aren’t required to provide us with any PII in order to use this Site, however, you may choose to provide PII to us such as your first and last name and email address in response to prompts featured on our Site. If you sign up for our email newsletter, we will need to collect your email address.
Non-Personally Identifiable Information: We may also collect and use information about your interactions with the Site in a manner and format that does not identify you as an individual (“Non-PII”). We may collect, use, and disclose the following types of Non-PII:
- Partners: We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access or use the Site. You may receive advertisements based on information relating to your access to and use of the Site and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and/or a laptop.
We also collect “Other Information” from you or other sources which is information not considered Personal Information. Other Information may include, but is not limited to, information such as:
- Article preferences, topics of interest or other content preferences by using “Like” or “Dislike” settings or creating lists;
- Display name, which in some cases may be different from your user name;
- “About” or other biographical information you provide and/or post on the sites;
- Comments or other information you post on the sites, which may also contain Personal Information if such information identifies you;
- Links to your social media accounts and websites;
- Browsing history, including the pages of the sites you visited and third party pages or sites you visited;
- Device type, settings and software used;
- Device identification number (“Device ID”), which is a distinctive number associated with a mobile device;
- “Advertising ID”, which is a unique, user-resettable identification number for advertising associated with a device (e.g. iOS uses the Identifier for Advertising and Android uses Google Advertising ID);
- Internet Protocol address (“IP Address”), which is a unique string of numbers automatically assigned to device whenever you access the Internet (but which may be identical to the IP Address of other users on the same network);
- Log files, which may include IP Addresses, browser type, internet service provider referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links;
- “Web Beacons”, which are electronic files that allow a website to count users who have visited that page or to access certain Cookies;
- “Pixels” or “Pixel Tags”, also known as clear GIFs, beacons, spotlight tags or web bugs, are a method for passing information from the user’s computer to a third party website;
- Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device;
- “Local Shared Objects”, which are pieces of data that websites may store on a user’s computer, including Brower Cookies and Local Storage; and
HOW WE COLLECT OR RECEIVE INFORMATION
We collect User Information across our Services, including as follows:
- If you sign up for an email subscription on our Services, we collect your email address and may also collect other information about your subscription preferences and interests;
- When you view or interact with our sites, we may collect certain data, including IP Address, language setting, operating system type, page you requested, Advertising ID, user agent, and time stamp;
- When you use the sites, we collect information about your search and click activity;
- We may collect or receive information about you when you sign up for a sweepstakes, contest or other giveaway or promotion (“Promotions”) offered by us or our partners;
- We may collect your user-generated content (for example, photos that you take or upload, comments that you provide or workout routines that you create, or URL links);
- When you make a purchase through our sites, we or our vendors may also collect your information as set forth below under WHAT INFORMATION WE SHARE WITH THIRD PARTIES;
- When you send an email to us, we will receive your email address and other information associated with your request;
- If you use a third party connection or log-in (such as Facebook Connect or Google) in connection with the site, we may receive your name, email address and/or profile photo for those third party services or other information available about you or collected from you on those services; and
- We may also supplement the User Information we collect from you with information from third parties, including third party vendors, affiliate network operators, referral sources, social networking sites or services (such as Facebook), and publicly-available sources.
COOKIES AND WEB BEACONS
We (and third parties with whom we partner) may also deliver a file known as a web beacon, pixel or pixel tag (i.e., “Web Beacons”) to you through our sites. Web Beacons are small, invisible graphic images that may be used on the site interface or in emails relating to the site to collect certain information and monitor user activity on the site interface, such as to count visits, access Cookies, understand usage effectiveness and to determine if an email has been opened and acted upon. “Pixels” or “Pixel Tags” also known as clear GIFs, beacons, spotlight, tags or web bugs, are a method for passing information from the user’s computer to a third party website. We (and third parties with whom we partner) may deliver Web Beacons or Pixel Tags to you through our sites. Web Beacons allow ad networks, marketing partners and other service providers that we use to provide anonymized, aggregated auditing, research and reporting for us, for advertisers and our other partners. Web Beacons also enable ad networks and other partners to track your behavior for their own analysis and use, and to serve targeted advertisements to you when you visit other websites or platforms. These Web Beacons enable third party companies to view, edit, or set their own Cookies when you visit the site, just as if you had visited a web page from their site.
HOW WE USE YOUR INFORMATION
The Data concerning the User is collected to allow us to improve our User Experience and Site Performance, as well as for the following purposes: Contacting the User and Analytics.
We may use the data we collect or receive to communicate directly with you. We may also send you emails containing newsletters, updates or special information. If you do not wish to receive email messages, we will give you a clear option to opt out or update your preferences. We may also combine your Personal Identifiable Information with third-party analytics information to build a broader profile of our Users.
User Information is used by MAN HE and its partners, which includes using such information to:
- Connect you across multiple devices or platforms where you are accessing our content;
- Customize the user experience to provide advertisements, content, features or recommendations on the sites or on other platforms (for example, social media platforms) that match your interests;
- Send you notices, updates and other administrative messages;
- Process transactions and send you related information;
- Send emails or newsletters to you, which may also offer or advertise MAN HE or third party products and/or services;
- Administer or communicate with you about Promotions;
- Link or combine information we receive from third parties to help provide you with better service;
- Detect, investigate and/or prevent fraudulent, unauthorized, or illegal activity;
- Analyze and monitor how our users utilize the site; and
We may also receive certain data (on an individual and/or aggregated basis) collected by our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) through the use of Pixel Tags, e-tags, IP Addresses, Local Shared Objects, Local Storage, and Browser cookies, which allows us to:
- Analyze trends across our user base;
- Collect and store information such as user settings;
- Supplement our server logs and other methods of traffic and response measurement;
- Track users’ location and movements around the sites; and
- Improve our understanding of traffic on the sites, visitor behavior, and responses to advertising and promotional campaigns.
MAN HE also works with third parties to provide analytics information regarding your usage of our sites or to help us track the advertisements that are delivered to you to determine the effectiveness of advertising on our sites. We may also link this information to User Information.
WHAT INFORMATION WE SHARE WITH THIRD PARTIES
Certain third party vendors and partners authorized by Man He (including, but not limited to, advertisers, advertising agencies, ad networks, ad measurement providers, and other marketing and advertising service providers and partners) (“Advertisers”) may collect information about you in order to provide you with relevant advertising on the sites and on platforms and media channels, and to analyze the performance of advertising campaigns. These Advertisers may use tracking technologies such as Cookies, Web Beacons, and other similar technologies, and may collect many different kinds of data, such as your IP Address, Device ID, Advertising ID and Precise Location Data where made available by your mobile device. The specific Advertisers we work with are subject to change at any time. For a list of some of the applicable providers or for more details on opting out of tracking for advertising purposes, go to our Cookie Consent Tool by clicking on the button in the lower right corner of your screen labeled “Cookie Consent”. The use of tracking technologies by these third parties is subject to their own privacy policies.
We may also sell or transfer Interaction Data to certain Advertisers who will use this data to serve ads that they believe are relevant to your interests. Some of these third parties may combine the Interaction Data with their own data about you to form a more detailed picture. We may also share your information with Advertisers for the purpose of allowing them or their clients to send you marketing communications related to your use of the site, their services or programs featured and/or advertised on the site (e.g., through ads or Promotions), or their products, services and/or programs generally.
Some of our sites may use Facebook and Instagram features and tools, including Pixel Tags, which send data regarding your use of the site to Facebook and/or Instagram for the purpose of tracking your interaction with the site and with our brand on Facebook and Instagram, and to create custom audiences on the Facebook and/or Instagram platforms. Facebook and Instagram link the data collected on our sites with your account on their platforms and we and/or our Advertisers may use that data to serve you with advertisements both on and off of Facebook and Instagram.
We may provide certain Advertisers with information regarding your interactions with our emails and newsletters or as to whether your information matches certain information held by the Advertiser and/or their customers. Those Advertisers may combine this data with information they collect for their own marketing purposes and in turn, may provide this information to their customers for their customers’ marketing purposes.
In order to help us sell advertising on the sites and otherwise publicize MAN HE and its Owned and Operated sites, we may share aggregate statistics that describe our online audience. Those statistics are often based on the information you provide when you subscribe, register, or browse the sites and describe, among other things, the demographics of our visitors.
THIRD PARTY SERVICE PROVIDERS
We employ or utilize the services of other third party vendors, consultants and service providers who need access to your User Information (such as your name, address, email, or other identifiers) in order to enable them to perform services on our behalf or to provide us with additional information necessary to provide you one of our sites to you. We use third party vendors for a variety of services across our sites, such as email message deployment, email address validation, subscription fulfillment, research, statistical analysis, cross-device user tracking, data and website hosting, marketing, advertising, and other data and transaction processing.
We also engage third party service providers for the purpose of processing payments for subscriptions, to fulfill your orders for product purchases, to honor your request to be removed from promotional mailings, and to monitor, analyze and prevent fraudulent traffic or other suspicious activities on our sites or on other services.
In addition to receiving your User Information from us, our service providers may also:
- Collect information directly from you and/or your device, such as your IP Address, Device ID, Advertising ID, and information about your browser or operating system;
- Combine User Information about you received from Man He with information about you from other sites or services; and/or
- Place or recognize a unique Cookie or other tracking mechanism on your browser.
THIRD PARTY PARTNERS AND WEBSITES
SOCIAL PLUG-INS AND EMBEDS
USER PROFILES AND SUBMISSIONS
Certain User Information from your profile such as your user name, display name, biographical information, or any comments or video or image content that you have uploaded to the sites may be displayed to other users to facilitate user interaction within the site or address your request for services. In some applications, information you share in your profile will be publicly available to other users.
THIRD PARTY OFFERS
In connection with some advertising campaigns or otherwise in connection with the sites, We may create and/or distribute custom digital promotional cards that you can elect to save into your digital wallet on your mobile device (examples of such digital wallets include Apple Wallet and Android Pay), which may feature a coupon, rebate, promotional discount or other offer from an advertiser or sponsor and/or MAN HE (each an “Offer”). When you engage with, download, share, or redeem an Offer, certain information about you may be collected by our third party advertising partners, including, but not limited to, data about your device such as user agent, operating system, advertising identifiers, Device IDs, Precise Location Data, and other data about your interaction with such Offer. Certain information may also be collected by or shared with third party providers who offer mobile wallet services on your device (for example, Apple for Apple Wallet or Google for Android Pay). The collection and use of such data by these third parties is subject to their respective terms and privacy policies. MAN HE is not responsible for any applicable third-party terms or policies and you should review them carefully. To opt out of such third party Offers, see the section below entitled HOW YOU CAN CHANGE OR CONTROL WHAT IS COLLECTED.
We may share your User Information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where User Information may be disclosed or transferred as one of our business assets.
ENFORCEMENT OF TERMS AND POLICIES
PROTECTION OF MAN HE AND OTHERS
We may access, read, preserve, and disclose any User Information where we reasonably believe a disclosure is necessary to comply with law or court order; or protect the rights, property, or safety of Man He, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
WITH YOUR CONSENT
We may share your User Information in other circumstances with your consent, for example when you have chosen to link an account with our Services with a social media network like Facebook or Google.
HOW YOU CAN CHANGE OR CONTROL WHAT IS COLLECTED
CHANGING YOUR ACCOUNT SETTINGS
You may add, update or delete information through your user account settings, which limits the ability of other users to see the information in your user profile. The information you can view, update, or delete may be different depending on which area of the site you are using and may also change as the Services change.
You can usually instruct your browser by changing its settings to stop accepting Cookies or to prompt you before accepting a Cookie from our sites that you visit. If you choose to disable Cookies, you may not be able to use all portions of the site or all functionality of the site. For more details on opting out of tracking for advertising purposes, go to our Cookie Consent Tool by clicking on the button in the lower right corner of your screen labeled “Cookie Consent”.
PRECISE LOCATION DATA
You may opt out of having your Precise Location Data collected us at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).
Newsletter and email subscriptions
You may adjust the “Settings” on your mobile device settings (or within the “profile” tab of certain applications) to disable push notifications for any of our sites for which you would like to stop receiving such notifications. You may adjust the “Notification” settings usually found in your browser “Preferences” or “Settings” to block or remove certain browser-based push notifications.
THIRD PARTY OFFERS
To remove Offers (described in the section above entitled “WHAT INFORMATION WE SHARE WITH THIRD PARTIES“) from your mobile device, go into your mobile wallet and delete or remove the applicable Offer. When you remove the Offer from your mobile wallet, your data will no longer be collected by MAN HE or its partners in connection with such Offer. To opt out of the collection of Precise Location Data by third parties in connection with Offers in your mobile wallet, go to the privacy settings on your device and turn off location data collection for the mobile wallet.
In accordance with the California Online Privacy Protection Act (see California Civil Code Sections 1798.83-1798.84), California residents are entitled to ask us for a notice identifying the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.
DO NOT TRACK
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our website.
OTHER USEFUL INFORMATION REGARDING YOUR PRIVACY
We use commercially reasonable safeguards to preserve the integrity and security of information collected and maintained through our sites. However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the site may not be accessed, disclosed, altered, or destroyed by unauthorized persons or hardware or software failure. You are ultimately responsible for the security of your email address and password.
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our Site, products and content are all directed to people who are at least 13 years old or older. The sites are not directed to children under 13, and we do not knowingly collect or solicit personally identifiable information from anyone under the age of 13. If you are under 13, please do not attempt to register for the sites or send any information about yourself to us.
Your User Information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, MAN HE transfers personal information to the United States and processes it there. By submitting such information, you consent to that transfer.
The time period for which we keep information varies according to the information’s use. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
GDPR COMPLIANCE FOR EUROPEAN UNION (EU) USERS ONLY
For Users located in the European Union, all processing of Personal Data performed in accordance with privacy rights and regulations following the General Data Protection Regulation (GDPR), and our data processing will take place in accordance with the GDPR.
By visiting this Site, EU Users will need to consent to the collection and use of your Personal Data as described herein. For users in the EU, you can update your consent choices by clicking here. If you do not agree with the terms set out herein, please do not visit this Site. As required by applicable law in the EU, we will seek your explicit consent to process Personal Data collected on this Site or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the full use of this Site may not be possible.
Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in promoted products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between the Site and yourself. We may also share such information with service vendors or contractors in order to provide a requested service or transaction in order to analyze Visitor behavior on our Site.
We gather data about visits to the Site, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.
We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.