1. GENERAL STATEMENTS
2. INFORMATION WE COLLECT AND HOW WE USE IT
How Proper Uses Your Information
We generally use your information to:
1. Facilitate the creation of and to secure your User Account (as defined below) on the Services;
2. Identify you as a user in our system;
3. Provide, personalize, and improve the Services;
4. Provide feedback and user base demographics to third-party businesses listed on the Websites or Services;
5. Communicate with you about your use of the Services;
6. Develop new products and Services,
7. Track usage of the Websites and Services;
8. Customize the advertising you view and recommend content;
9. Backup our systems and allow for disaster recovery;
10. Fulfill your requests and provide customer support;
11. Send newsletters, surveys, offers and promotional materials related to the Services and your user preferences and behaviors and for other marketing purposes of Proper using your contact information;
12. Protect, investigate, prevent and potentially take action against possible fraudulent, unauthorized, or illegal activities;
13. Respond to claims that Website content is inauthentic, counterfeit, or otherwise violates the rights of third parties;
14. Respond to your requests for customer service;
15. Protect our rights and the rights of other users;
We may also use your information to verify your geographic location. We may use your geographic location data to personalize and improve our Websites or Services, to recommend content, or determine whether the information you have requested is available in your location.
How Proper Discloses Your Information
1. We may share your personal information with your consent or at your direction, including with third parties fulfilling orders or requests you place on our Websites.
2. We may also share your information with others who perform services on our behalf.
3. We also may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses or to protect Proper, our Websites, and Services; or any rights, property, or personal safety of Proper or others.
5. We may share your information with any of our affiliates.
We may also share aggregated and reasonably anonymized data with our partners, advertisers, and other third parties. You acknowledge and agree that the Websites can serve as portals to other businesses and consumers. Any requests, orders, or interactions you engage in with other businesses and consumers may necessitate the provision of information to such other party.
Information We May Collect
1. Account Information: If you create an account on any of the Websites or Services (a “User Account”), we may store and use your full name, e-mail address, home address, phone number, zip code, and other information you may provide with your User Account, such as your gender and birth date. Your first name and last initial, as well as any photo you submit through the registration process, may be publicly displayed as part of your User Account profile. We may also store and use information regarding your means of age verification (e.g., drivers license) or medical marijuana recommendation, including your recommending doctor’s name and license number, contact information, verification methodology, and verification number. We may also store information on your order history and preferences with respect to orders placed from your account.
2. Public Content: The information that you contribute through or post on the Websites or Services is intended for public consumption, including your reviews, tips, photos, videos, check-ins, comments, likes, posts, events, bookmarks, friends, lists, compliments, and basic User Account profile information. We may display this information through the Websites or Services, share it with businesses, and further distribute it to a wider audience through third-party sites and services.
3. Communications: When you sign up for a User Account or use certain features, you are opting to receive messages from other Proper users, businesses, and Proper itself. While you can manage some of your e-mail preferences, please note that you cannot opt out of receiving certain administrative, transactional, or legal messages from Proper. We may also track your actions in response to the messages you receive from Proper or through the Websites or Services, such as whether you deleted, opened, or forwarded such messages. If you exchange messages with others through the Websites or Services, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to the operation and use of the Websites or Services. We may not deliver messages that we believe are objectionable, such as spam messages or requests to exchange reviews for compensation. If you send or receive messages through the Websites or Services via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, e-mails, and other electronic messages, or in person. If you are a representative of a business listed on Proper, we may contact you, including by phone or e-mail, using the contact information you provide us, make publicly available, or that we have on record for your business.
4. Transactional Information: If you initiate a transaction through any of our Websites or Services, to the extent applicable (the “Transactable Sites”), we may collect and store information about you, such as your name, phone number, address, e-mail, and credit card information, as well as any other information you provide to us, in order to process your transaction, send communications about them to you, and populate forms for future transactions. This information may be shared with third parties for the same purposes. Proper does not disclose your personal information to third parties for the purpose of directly marketing their services to you unless you first agree to such disclosure that may advertise content directly to you on behalf of such parties. When you submit credit card numbers, we encrypt that information using industry standard technology. If you write reviews about businesses with which you transact through the Websites or Services, we may publicly display the fact that you transacted with those businesses.
a. We collect non-personal information from you while you are browsing in the Websites. This information may include IP addresses to help analyze system administration, to gather broad demographic information, to enable ads to reach the right individuals, to report non-personal information to our advertisers, and to monitor the level of activity on Proper. The information we collect from you visiting the Transactable Sites may include the URLs they came from, their IP addresses, the date and time of their visit or order, the number of visits and orders, the number of visits per browsing session, the server type, the operating system and browser type used to come to the site, the country, state, and telephone area code where their servers are located, the pages and page titles of our site that visitors viewed during their visit, whether the visitor’s computer is enabled for Java or cookies, browser language, applications and plug-ins, and any search terms entered on Proper. We may also collect and store data that may be considered personal medical information, including regarding orders you prepare to place or actually place through any of the Transactable Sites.
5. Activity: We may store information about your use of the Websites or Services, such as your search activity, the pages you view, the actions you take, the date and time of your visit, businesses you call or e-mail using our mobile applications, and purchases you make through the Transactable Sites. We also may store information that your computer or mobile device provides to us in connection with your use of the Websites, Services, or Transactable Sites, such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location), and requested and referring URLs. You may be able to disallow our use of certain location data through your device or browser settings, for example by disabling “Location Services” for the Proper application in iOS privacy settings. We note that disabling Location Services may adversely impact the Website or Services experience and functionality and enabling such services may be necessary in some cases to allow certain transactions.
Our uses for these technologies fall into one of the following general categories:
4. Advertising or Targeting-Related: We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third-party sites. This involves using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
Managing Cookies: It may be possible to disable some (but not all) Cookies through your device or browser settings, but doing so may affect the functionality of the Websites, Services, and Transactable Sites. The method for disabling Cookies may vary by device and browser, but can usually be found in preferences or security settings. For flash cookies, you can manage your privacy settings by visiting the Adobe Macromedia site, located here.
4. THIRD PARTIES
Third parties may receive information about you as follows:
2. Service Providers: We may rely on third-party providers to support or provide some of the features and options that are available through the Websites, Services, or Transactable Sites. We may also rely on third-party providers to perform certain services for us in connection with your use of the Websites or Services, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, our own marketing of the Websites or Services, promotional and contest features, Transactable Sites’ product listings and brand management, and other functions. We may share information from or about you with these third-party providers so that they can perform their services or complete your requests. These third-party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third-party providers may also share this information with their subsidiaries, joint ventures, affiliates, partners, or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third-party providers, while preserving the look and feel of the Websites or Services. In such cases, please note that the information you provide is being provided to the third party.
3. Aggregate Information: We may share user information in the aggregate with third parties, such as advertisers, brand managers, and content distributors. For example, we may disclose the number of users that have been exposed to, or clicked on, advertisements, or certain products available in the Transactable Sites or the general characteristics of such users.
5. Businesses on Proper: We may share information from or about you (such as your age and gender, your devices, and your use of the Websites, Services, and/or Transactable Sites (such as which businesses you bookmark or call)) with businesses listed on Proper. You may adjust your settings to increase or decrease the amount of information we share. Keep in mind that businesses may see your Public Content (as defined in Section 2 above) and receive information about your transactions with them in the Transactable Sites, regardless of your settings. Additionally, if you make a phone call to a business through or in connection with your use of the Websites or Services, we may share basic information about your call with the business that you contacted, such as the date and time of your call and your phone number (and other information that would have been available to the business had you contacted them directly, and not through the Websites or Services). You may be able to limit our ability to collect and share your phone number through your phone’s settings or phone service provider.
6. Investigations: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with federal, state, or local legal process and legally binding law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Websites, Services, or Transactable Sites; or (c) protects our rights, reputation, property, or that of our users, affiliates, clients, partners, or the public, such as disclosures in connection with our Consumer Alerts program. If you flag or otherwise complain to Proper about content available through the Websites, Services, or items on the Transactable Sites, we may share the substance of your complaint with the contributor of that content or product in order to provide an opportunity for the contributor to respond and/or remedy the situation.
8. Sweepstakes, Contests and Promotions: We may sometimes offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Websites or Services that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including allowing the sponsor of the Promotion to use your name, voice, and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
• Please Note: If you agree to accept a Promotion from our third-party service providers or any third-party merchant, then you will receive e-mails separately from them and all information that you choose to disclose to them will be subject to their individual and separate privacy policies. If you later decide that you no longer want to receive their e-mails, then you will need to follow their own specific opt-out instructions. Following our directions for opting out of e-mail notifications and disclosure of personal information will not opt you out of third-party disclosures and related promotional communications.
5. CHANGES TO YOUR PROFILE AND EMAIL PREFERENCES
We believe you should have the ability to access and edit the personal information you provide to us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information that was provided as part of your registration with our Websites or Services. The Websites or Services may allow you to review, correct, or update personal information you have provided through the Websites or Services’ forms or otherwise. We will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Also, any public postings or other communications you have made on the Websites or Services such as in forums or blogs cannot generally be removed. When you edit your personal information or change your preferences on the Websites or Services, information that you remove may persist internally for our own administrative purposes.
You may cancel or modify the e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your User Account and changing your communication preferences. This will not affect subsequent subscriptions, and if your opt-out preferences are limited to certain types of e-mails, the opt-out will be so limited. Subsequent or different subscriptions will remain unaffected. Please note that we reserve the right to send you certain communications relating to your User Account or use of our Websites or Services, such as administrative and service announcements, and these transactional User Account messages may be unaffected even if you choose to opt out from receiving our marketing communications.
For those users utilizing the Transactable Sites’ online ordering feature, you can review, change, or delete the information you have submitted. You may ask to have information on your User Account deleted or removed; however, because we keep track of past purchases, you cannot delete information associated with past purchases. Also, as a security measure, we “back up” the data stored on our systems, ensuring that such prior information cannot be completely removed from our databases. As a result, you should not expect that all of your personal information will be completely removed from our backed-up or archived databases.
6. DATA RETENTION AND USER ACCOUNT TERMINATION
7. CUSTOMER DATA
8. CHILDREN USING THE WEBSITES OR SERVICES
The Websites or Services are intended for adults only and require that users be no less than twenty-one (21) years of age. Individuals under the age of twenty-one (21) are prohibited from creating a User Account and profile, accessing the Websites or Services, and/or purchasing products on the Transactable Sites. If you become aware that an underage user has created a User Account using false, stolen, or otherwise misleading information, please contact us immediately at firstname.lastname@example.org.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. This includes using Secure Sockets Layer (SSL) software, which is software that encrypts the information you input. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Within the Transactable Sites, your information is kept on password-protected, limited access servers. Wherever possible and applicable, the Transactable Sites’ servers reside behind a corporate firewall that maintains controls on access to the system from both our internal network and the Internet.
10. CONTACT INFORMATION
11. INTERNATIONAL DATA TRANSFER
Please note that we take the privacy of our users seriously and therefore take steps to safeguard your personal information, including assuring an adequate level of data protection in accordance with international standards. If you would like additional information about your personal data and its use in connection with the Websites and Services, including revising any incorrect information, please contact the Data Privacy Manager at the address in Section 10 above. We will take such steps as we deem necessary to confirm your identity before sharing any personal data with you. We will attempt to respond to proper and confirmed requests relating to personal data within thirty (30) days, or as otherwise required by applicable law. If you are not satisfied with the way your request was handled, you may refer your request to your country’s data management authority. In the European Union, any such request should be directed to the Data Protection Authority in your EU Member State.
12. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at email@example.com. Please allow up to thirty (30) days for a response.
13. DO NOT TRACK
Proper does track its customers over time and across third-party websites to provide intelligent advertising, and does not respond to Do Not Track (“DNT”) signals. In addition, some third-party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your web browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. Please review your web browser’s internet options for more details.
Updated November 13, 2018