PRIVACY NOTICE/YOUR PRIVACY RIGHTS
Effective Date: October 15, 2024
LAST UPDATED October 15, 2024
Charlie Company Holdings Inc., together with its subsidiaries and affiliates (collectively, "Company" "us," "we," or "our") is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events and purchases; and other online and offline interactions.
This Privacy Notice applies to information we collect about individual consumers, such as general website visitors (“Individuals”) as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions (“Business Contacts”). However, this Privacy Notice does not apply to information about our current/former employees, applicants, and other individuals who interact with us for employment-related purposes. This Privacy Notice also does not apply to data that we handle on behalf of and under the instructions of our business customers.
Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.
Changes: We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates.
1. Sources of Personal Data
We collect Personal Data about you from the following sources:
A. Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; register for an event; interact with us in person; sign up for offers or newsletters; communicate with us; place orders; enter sweepstakes; complete surveys; apply for a job; or sign up for an account or other services.
B. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties as described in Section 5 (Cookies and Other Tracking Technologies).
C. From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies, or other parties who interact with us.
D. From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.
We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.
2. Types of Personal Data We Collect
We may collect the following types of Personal Data. Except as otherwise specified, we may collect this Personal Data from both Individuals and Business Contacts.
3. How We Use Personal Data
We may use Personal Data for the following purposes:
- To provide you or your company products and services, such as making our Digital Properties and other products and services available to you; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); and providing similar services or otherwise facilitating your relationship with us.
- For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
- For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services, including the Digital Properties; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
- For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
- In connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
- For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us, including our Digital Properties; to hold sweepstakes, giveaways, and contests; and to send you newsletters, surveys, questionnaires, promotions, or information about events.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
4. How We Disclose Personal Data
We may disclose Personal Data to third parties, including the categories of recipients described below:
- Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
- Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
- Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
- Vendors necessary to complete transactions you request, such as shipping companies, payment processors, and logistics providers.
- Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements; to enforce or apply our terms, agreements or policies; and to protect our, your, our customers’, or other third parties' safety, property, or rights.
- Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
- Business partners that may use Personal Data for their own purposes, such as:
- The public, such as when you have an opportunity to make comments regarding us or our products or services that we may share with the public, including comments on our blog posts and posts on our forums. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
- Entities to which you have consented to the disclosure.
We may disclose anonymized, de-identified, or aggregated information for any purpose permitted by law.
5. Cookies and Other Tracking Technologies
The Company and our authorized third parties use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:
- The types of tracking technologies we use and the purposes for which we use them
- The types of information we collect using these technologies
- How we disclose or make information available to others
- Choices you may have regarding these technologies
- Types of cookies and tracking technologies we use
- Purposes for using these technologies
- Information collected
- Disclosures of your information
10. Contact Information
If you have questions regarding this Privacy Notice, please contact us at:
:
user.privacy.requests@charliecompanymedia.com
: Charlie Company Holdings, Inc. Re: Privacy
1 Manhattanville Rd, Suite 202,
Purchase, NY 10577
Phone
: (203) 861-0900.
11. Supplemental Information for Residents of California, Colorado, and Other U.S. States
- Data Subject Rights
- Additional Data Processing Disclosures for California Residents
| Categories of Personal Data We Collect | Categories of Third Parties With Whom We Disclose Personal Data for a Business Purpose | Categories of Third Parties to Whom Personal Data is Sold/Shared for Targeted Advertising |
| Identifiers (Section 2.A) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co- branded products and services |
| Records about you (Section 2.B) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Demographic information (Section 2.C) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Commercial information (Section 2.D) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Internet or other electronic network activity (Section 2.E) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Geolocation data (Section 2.F) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Audio, electronic, visual, or other sensory information (Section 2.G) | Affiliates and subsidiaries Service providers Professional consultants Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Not sold or shared |
| Professional or employment-related information (Section 2.H) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Education information (Section 2.I) | Affiliates and subsidiaries Service providers Professional consultants Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Not sold or shared |
| Inferences (Section 2.J) | Affiliates and subsidiaries Service providers Professional consultants Vendors necessary to complete transactions you request Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platforms Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes Partners who work with us on promotional or sponsorship opportunities, including sweepstakes and co-branded products and services |
| Sensitive personal information (Section 2.K) | Affiliates and subsidiaries Service providers Professional consultants Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure | Not sold or shared |