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Privacy Policy
Last Modified: 5/6/24
SCOPE OF THIS POLICY
This privacy policy describes the processing of information provided or collected on the sites and applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms. It also describes the processing of information provided to us or collected by us offline in our physical properties, such as in our conferences. We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Those terms are to be read in conjunction with this policy.
Please keep in mind that when you provide information to us on a third-party site or platform, the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.
We collect two basic types of information – personal information (as defined in this policy) and anonymous information (as defined in this policy) – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy). In particular, we collect:
• Registration information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, gender, date of birth, email address, username, and password;
• Transaction information you provide when you request information, contact Support Services, or purchase, return, request, or exchange a product or service from us, such as your postal address, telephone number, and payment information;
• Information you provide in public forums on our sites and applications, such as your public posts;
• Information sent either one-to-one or within a limited group using our message, chat, post, or similar functionality, where we are permitted by applicable law to collect this information;
• Information we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices;
• Location information, including precise or approximate location information provided by a mobile or other device interacting with one of our sites, applications, or physical properties (including through beacon technologies), or associated with your IP address or other online or device identifier, where we are permitted by law to process this information;
• Activity information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences;
• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, or connect with our wireless Internet access services and other similar technologies, including your browser or device type, unique device identifier, and IP address;
• Still or video images captured by cameras or readers on or around our physical properties; and
• We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to guest surveys, visit our physical properties, call our support services phone numbers, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing or using voice commands.
• We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.
• We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
• We acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.
We will not share your personal information with a third party outside of SEAL except in limited circumstances, including:
• When you allow us to share your personal information with another company, by electing to share your personal information with carefully selected companies so that they can send you offers and promotions about their products and services;
• When you direct us to share your personal information with another company to fulfill your request;
• When you direct us to share your personal information with third-party sites or platforms, such as social networking sites.
• When we work with service providers performing services on our behalf; however, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law;
• When we provide you with relevant advertising on third-party sites and applications, we may share limited personal information about you, such as certain identifiers or hashed email address, with third parties. We may also share such information to provide you with and to measure relevant third-party advertising on our sites and applications.
• When we share your personal information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.
• Please note that, except as otherwise stated above, once we share your personal information with another company in the above circumstances, the information received by the other company is controlled by that company and becomes subject to its privacy practices.
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. In accordance with applicable law, your controls and choices may include:
• Correcting, updating, and deleting your registration account;
• Choosing or changing your choices for subscriptions, newsletters, and alerts;
• Choosing whether to receive from us offers and promotions for our products and services, or products and services that we think may be of interest to you;
• Choosing whether we share your personal information with other companies so they can send you offers and promotions about their products and services;
• Controlling targeted advertising by clicking on “Do Not Sell or Share My Personal Information” or “Manage Your Cookie Settings” in our website footers or application settings;
• Controlling targeted advertising from many ad networks and partners; data exchanges; and marketing analytics and digital advertising and marketing service providers;
• Choosing to control targeted advertising you receive within applications by using the settings and choices made available to you through your device(s), for example, by opting out of interest based ads;
• Requesting removal of your personal information from a public forum on one of our sites or application; and
• Requesting access to the personal information we hold about you and that we amend or delete it.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact Support Services.
We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our sites and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:
• Notifying parents about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
• In accordance with applicable law, and our practices, obtaining consent from parents for the collection of personal information from their children, or for sending information about our products and services directly to their children;
• Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
• Giving parents access or the ability to request access to personal information we have collected from their children and the ability to request that the personal information be changed or deleted.
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.
From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.
If you have a comment or question about this privacy policy, please contact Support Services.
CALIFORNIA PRIVACY POLICY
This notice to California residents is provided under California law. It provides our “Notice at Collection,” provides certain mandated disclosures about our treatment of California residents’ information, both online and offline, explains your privacy rights, and provides our “Notice of Financial Incentives.”
NOTICE AT COLLECTION
We may collect the following categories of personal information (as defined in the California Consumer Privacy Act (CCPA) and the California Customer Records statute), including sensitive personal information (as defined in the CCPA):
• Identifiers, such as name, email address, username and password, postal address, telephone number, signature, government-issued identifier, license plate number, IP address, and other similar identifiers.
• Characteristics of protected classifications and demographic information, such as gender, age, race, disability status, sexual orientation, gender identity, military/veteran status, marital status, national origin, and medical information.
• Commercial information, including information about your interests and consuming history or tendencies, such as products or services considered; transaction information when you request information, contact Guest Services, or purchase, return, request or exchange a product or service, including payment card information or other financial information; information provided in response to surveys or other research conducted on our behalf; and information you provide in public forums.
• Internet or other electronic network activity information, including information regarding your interactions with us online and information we obtain from third parties about use of our applications on third-party platforms or devices.
• Geolocation data, including precise or approximate location information provided by a mobile device or other device or product interacting with or detected by our sites, applications, or physical properties, where we are permitted by law to process this information.
• Audio, electronic, visual, or similar information, including telephone call recordings, other voice recordings, and still or video images captured by cameras or readers on or around our physical properties.
• Inferences based on the above.
We collect this information so that we can best serve you, including to fulfill your requests and to share offers or information that we think you may be interested in. We generally collect and use the above-listed categories of personal information to provide and manage our sites, applications, products, and services, and for other business or commercial purposes, such as advertising, marketing, and to improve our products and services.
Certain data collection on our sites and applications by third parties for purposes of interest-based advertising and social media tools may be a “sale” or “sharing” under California privacy law. As defined by California law, we “sold” or “shared” certain data elements within the following categories of personal information: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above.
If you would like to opt out of the sale or sharing of your personal information, you may click the “Do Not Sell or Share My Personal Information” link in our website footers or in our application settings. Please note that your opt-out choice is specific to the digital property and to the device and browser you are using.
We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our Privacy Policy, including to satisfy legal or reporting requirements. What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.
More information, including a description of your legal rights, can be found in the “California Privacy Rights” section below.
ADDITIONAL PRIVACY MANDATORY DISCLOSURES
We also make the following disclosures for purposes of compliance with California privacy law:
• We collected the following categories of personal information in the last 12 months: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.
• The sources of personal information from whom we collected are: directly from our guests, third-party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.
• The business or commercial purposes of collecting personal information are as summarized in our “Notice at Collection” section, and as described in more detail in our Privacy Policy.
• We disclosed certain data elements within the following categories of personal information for a business purpose in the last 12 months: identifiers, characteristics of protected classifications and demographic information, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to business partners, service providers, government entities, and other third parties.
• As defined by applicable law, we “sold” or “shared” certain data elements within the following categories of personal information in the last 12 months: identifiers, demographic information, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above. We “sold” or “shared” each category to or with entities who provide advertising, marketing, or audience measurement; other online third-party branded tools or functionality (such as maps or video players); and social networks.
• The business or commercial purposes of “selling” or “sharing” personal information is to assist us with advertising, marketing, audience measurement, and other functionality on our digital properties.
• We do not “sell” or “share” the personal information of known minors under 16 years of age.
• We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations.
YOUR CALIFORNIA PRIVACY RIGHTS
Right to Know
You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.
Right to Access
You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
Right to Delete
You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
Right to Correct
You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
Right to Opt Out of Sale or Sharing of Personal Information
You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by applicable law).
Removal of Content
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.
Shine the Light
California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of SEAL to third parties for the third parties’ direct marketing purposes. SEAL does not share your personal information with other companies or others outside SEAL for those parties’ direct marketing use unless you elect that we do so.
Right Not to Receive Discriminatory Treatment
You have the right not to receive discriminatory treatment for the exercise of your privacy rights. If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information. For example, if you exercise your right to opt out of “sale” or “sharing” of your ”personal information,” the ads you view may not be tailored to your interests.
EXERCISING YOUR CALIFORNIA PRIVACY RIGHTS
Making Requests to Know, Access, Delete, or Correct Your Personal Information
To make a request to know or to make an access, deletion, or correction request, please visit seal.org. Before completing your request, we may need to verify your identity. We will send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity.
Making Requests to Opt Out of the Sale or Sharing of Personal Information
To submit a request to “opt out” of the “sale” or “sharing” of your “personal information,” you may click the “Do Not Sell or Share My Personal Information” link in our website footers or in our application settings, or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.
Instructions for Using an Authorized Agent to Make Requests
You may use an authorized agent to submit a request to know or an access, deletion, correction, or opt-out request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests at seal.org.
Making Requests for Removal of Content
California residents under the age of 18 may make requests to remove content by sending an email with a detailed description of the specific content or information to be removed to seal.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Making Shine the Light Request
To make a request for information under the Shine the Light Act, please send an email to seal.org.
CONTACT INFORMATION
If you have a question about our privacy policies and information practices, please send an email to seal.org.