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Privacy Policy

Effective from: 21 December 2023

At Stroop, we take privacy seriously and we respect the privacy concerns of our community of users. This Privacy Policy (the “Privacy Policy”) describes how Stroop (“we,” “us,” or “our”) collect, use, disclose, and otherwise process personal information in connection with our websites (the “Sites”) and the related content, services, products, and other features and functionality offered on or through those Sites (collectively, the “Services”). 

What personal information do we collect? 

​Information you provide to us

The personal information we collect from, and about, you may vary depending on how you engage with our Services and the information you provide voluntarily. We may collect personal information directly from you or otherwise in connection with your use of the Services, such as:

  • Contact Information: 
    Including your name, contact details (such as a postal address and email address) and communication preferences. 
     

  • Inquiry Information: 
    Including information provided in messages sent through forms or surveys, to our email addresses, or via phone. This also may include information provided when you sign up for our newsletters.
     

  • Account Information: 
    Including name, username, account ID, date of birth, contact information, profile information, saved, “liked,” or bookmarked items (e.g., articles or recipes)
     

  • Demographic Information: 
    Including age.
     

  • User-Generated Content: 
    Including personal information you choose to provide about yourself when you participate in discussions on the Services, post comments or reviews, and participate in any Services. Please be aware that information you post may be viewed, used, or captured by anyone who visits the Services, therefore, you should avoid posting sensitive personal information that you would not want to be available to the public.
     

  • Contest, Sweepstakes, and Survey Information: 
    Including information provided when you enter a contest or sweepstakes, information included in any responses submitted through surveys or questionnaires, or the content of any testimonials.

Information collected automatically

General

As is true of many digital properties, we and our third-party partners may automatically collect information you provide to us and information about your device and use of the Service when you visit or interact with our Services. We, and our third-party partners, use cookies and other tracking technologies (e.g., pixels, SDKs, APIs, scripts, location-identifying technologies, and logging technologies) in connection with our Services to collect and store the information described in this section (and otherwise expanded upon in other sections) for our, and our third-party partners’, purposes.

The type of information automatically collected includes:

  • Device data: 
    Including internet protocol (IP) address, operating system, device type and version, browser type and version, browser ID, the URL entered, the referring page, date/time of visit, other user agent string data, the time spent on our Services, and any errors that may occur during the visit to our Services. Device data may overlap with the other categories of data listed below.
     

  • Analytics/Usage data: 
    Including the path taken to our Services, through our Services, and when exiting our Services, usage and activity on or in connection with our Services (e.g., pages visited, links clicked, videos watched), metrics on how many emails we send are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels, as described further below). We may also use third-party tools to collect information you provide to us or information about how you use the Services, including mouse movements, scrolling, clicks, and keystroke activity on the Services and other browsing, search, or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat or other features through our Services.
     

  • Location data: 
    Including geographic location we or our third-party providers may collect, such as via permissions within the app operating system or browser functionality.
     

  • Advertising/Advertising measurement data: 
    Including data associated with your view of, or your clicks on, advertisements served on our Services, cookie IDs or other digital or proprietary identifiers (e.g., iOS IDFA, Google AAID) assigned to such device, and device metadata, analytics/usage data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns.  For more information on our and third-party partners’ data collection and online advertising practices, please see the “What are our third-party data collection and online advertising practices?” section of this Privacy Policy.

 

Note that we and our third-party partners may combine information that each of us collects automatically with other information about you, including information you choose to provide. See the “What controls do I have over my information?” section below to learn more about how you may limit or disable cookies or certain other tracking technologies on your device. For more information about how we and our third-party partners use these technologies and data for advertising purposes, please see “What are our third-party data collection and online advertising practices?” below.

 

Third-Party Sources

We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual. For example, we may receive the same categories of personal information described above from the following third parties:

  • Other users who interact with our services:
    We may receive your information from other users who interact with our Services.
     

  • Business partners:
    We may receive your information from our business partners, such as companies that offer their products or services on our Services or on other properties (e.g., digital properties, offline locations) or marketing/advertising and analytics partners, including third-party brands/agencies or other partners that facilitate the buying and selling of advertising inventory on our Services, measure of the effectiveness of those related ad campaigns, or inform business analytics (e.g., view rates, bounce rates, audience composition).
     

  • Social Media Networks:
    When an individual interacts with our Services through various social media networks, such as when someone logs in through a social network, “Likes” us on Facebook, or follows us or shares our content on Google, Facebook, Instagram, Twitter, or other social networks, we may receive some information from those social networks including your profile information and any other information you permit the social network to share with third parties. We use this information to allow you to log into your account, to communicate or interact with individuals on the social network, to better understand the demographics of our visitors, and to personalize content and advertising. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information or linking or connecting them to other services.
     

  • Information we receive from authentication services:
    Some parts of our Service may allow you to login through a third-party social network or authentication service such as Facebook or Google. These services will authenticate the individual’s identity and provide the option to share certain personal information with us, which could include a name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and the individual’s privacy settings on that third-party digital property. We use this information to authenticate the individual’s account, to provide our Services, to communicate with our users, and for advertising and marketing purposes.
     

  • Service Providers:
    Our service providers that perform services on our behalf, such as payment processors or survey and third parties who conduct marketing/advertising and analytics activities on our behalf, collect personal information and may share some or all of this information with us.
     

  • Information Providers:
    We may from time to time obtain information from third-party information providers to correct or supplement personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with an individual or obtain demographic information (e.g., interests, preferences).
     

  • Other sources:
    We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.

 

How do we use personal information?

We may use your information for various purposes, including:

  • To fulfill your requests and provide our Services to you:
    This includes:

    • Making our Services available to you;

    • Coordinating access to your account;

    • Responding to requests, suggestions, questions, and comments, and providing other types of user support;

    • Fulfilling your payments and transactions;

    • Sending you service/transaction-related messages, such as changes to your account;

    • Saving your reading lists, recipes, or other searches; and

    • Communicating about, and administering your participation in, events, conferences, programs, contests, surveys, polls, panels, questionnaires, and other offers or promotions.
       

  • To personalize your experience on our Services:
    This includes providing you with content or other products or services you might be interested in and de-emphasize content you’ve already read or viewed.
     

  • For marketing purposes:
    We may send you communications about new features, updates, products, and special offers.  We may also use your information to serve you ads about our products or other products or services we (or our advertising partners, such as other third-party brands/agencies) think you might find interesting. We may also use individual and aggregate information about you to inform our, and our third-party partners, marketing and advertising campaigns more broadly.  For more information on your choices about marketing communications, see the “What controls do I have over my information?” and “What are our third-party data collection and online advertising practices?” sections of this Privacy Policy.
     

  • To communicate with you:  
    For example, we may communicate with you about your account activities, such as by providing you transaction confirmations or alerting you when a subscription is up for renewal. If you register with us, we may enroll you in our email newsletters or other periodic electronic communications and may also send you user surveys and promotional communications. We may communicate with you by email, postal mail, telephone, text message, or other means. We may use push notifications on Apps to your mobile device. For more information on how to adjust your communications preferences, see “What controls do I have over my information?” below.
     

  • To monitor, improve, and develop our products and services:
    We may use your information to understand our users and to tailor or optimize our Services. For example, we may analyze statistics and trends to make our Services better and to develop or better personalize the Services or new services or features.
     

  • To protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law:
    We may use your information to protect our company, our affiliates, our customers, and our Services. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, protect and defend our rights and property, or the rights or safety of third parties, enforce our Terms of Use, this Privacy Policy, or agreements with third parties, detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law.  We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets and may use information in connection with or as an asset in such a corporate business transaction. Personal information may also be used in the event of insolvency, bankruptcy, or receivership.
     

  • For any other purposes with your consent, at your direction, or where notice is provided:
    We may use your personal information for any other purposes with your consent, at your direction, or where notice is otherwise provided.

 

How do we share personal information?

We may disclose personal information to third parties, including:

  • Third parties at your request:
    You may choose to share your activities on the Services with your friends through email, text, or on various social media networks.
     

  • Promotional partners:
    We may share information with third parties with whom we partner to provide contests, surveys, and sweepstakes, or other joint promotional activities.
     

  • Marketing and strategic business partners:
    We may share information with marketing/advertising, analytics, and other business partners (such as those that provide their own products or services on other properties) for purposes such as us or those entities providing you with information, undertaking marketing/advertising activities about products or services that may interest you, informing business analytics, or for other business or commercial purposes as may be further described in their privacy policies or our privacy policy.
     

  • Online advertising partners:
    We may share information with third-party online advertising partners or permit these partners to collect information from you on our Services to facilitate online advertising and related measurement/attribution activities.
     

  • The public:
    When you provide feedback or post user content on our Services (e.g., if you post a comment on an article or comment on our social media sites), your information (e.g., your first name, last initial, country of residence, and your comments) may be displayed on our Services or on our social media pages. When you engage with us on social media, we may tag your social media account or the social media account of others (e.g., to give photo credit to another user).
     

  • With your consent, at your direction, or where notice is provided:  
    In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing or where notice is otherwise provided.
     

  • Service Providers and Advisors:
    Personal information may be shared with third-party vendors and other service providers who perform services for us or on our behalf. This may include certain vendors and providers who engage in marketing or advertising activities, analytics, or provide mailing or email services, tax and accounting services, product fulfillment, delivery services, payments processing, data enhancement services, fraud prevention, web hosting, or analytic services.
     

  • Purchasers and third parties in connection with a business transaction:
    Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy, or related or similar proceedings.
     

  • Law enforcement, regulators and other parties for legal reasons:
    Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe that such action is necessary to:

    • Comply with the law and the reasonable requests of law enforcement;

    • To enforce our Terms of Use or to protect the security or integrity of our Services;

    • To exercise or protect the rights, property, or personal safety of our organization, our visitors, or others.

 

In connection with any of the above, we may share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you.

What are our third-party data collection and online advertising practices?

 

General

We, and our third-party partners, use information that we receive about you (e.g., that you provide to us or about your use of the Services, or that we receive from third parties) to serve advertisements more relevant to your interests, the content on which the ads will appear, or audiences similar to you, to optimize marketing and advertising campaigns more broadly, as well as to generate analytics and provide marketing/advertising-related services such as reporting, market research, and measurement/attribution. These third-party partners may include online advertising networks or exchanges, measurement/attribution companies, ad fraud verification companies, social media companies, or other advertising technology services (e.g., demand-side or sell-side platforms, ad servers, clean room providers).

 

How we collect this information

The information used for these advertising practices is typically collected through tracking technologies, such as cookies, web beacons/pixels, SDKs, APIs, embedded scripts, location-identifying technologies, logging technologies, and similar technologies, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, mobile ad ID or other digital identifier (e.g., iOS IDFA, Google AAID, cookie ID, click ID, other proprietary IDs such as open-source “universal IDs” or other ID solutions), geolocation, and other information, such as the advertising/advertising measurement data discussed further above in this Privacy Policy. These tools may also collect other information you provide to us or other information about how you use the Services, such as your mouse movements, scrolling, clicks, and keystroke activity on the Services and other browsing, search, or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat or other features through our Service.

We may share a common account identifier (such as a hashed or encrypted email address or user ID) or other information (such as phone number, which also is typically provided in hashed or encrypted format) with our third-party advertising partners to help identify you across devices. We may share this information using mechanisms such as API, direct file upload, server-to-server transfer, or integrating the tracking technologies of those partners (e.g., pixel).

 

How to exercise your choices regarding online ads

Please see the “What controls do I have over my information?” section below to learn how you can opt out of interest-based advertising.

 

More on social media platforms and advertising

Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter, or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We may display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn, and other social media platforms.  For example, these companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. As mentioned in the section above, we may share a unique identifier, such as a user ID or hashed or encrypted email address or phone number, with these platform providers or they may collect information from our website visitors through a pixel (or other mechanism, such as API, direct file upload, or server-to-server integration), in order to direct targeted advertising to you or to a custom audience (including “look-a-like” audiences, such as audiences that are similar to you or other users) on the social media platform.  These advertisements are governed by the privacy policies of those social media companies that provide them.  If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.

What controls do I have over my information? 

 

You may control your information in the following ways:

  • Access to, modification of or deletion of your information:
    You have the right to request access to your personal information, amendment/correction of inaccurate/incomplete personal information, or deletion of your personal information. In order to better protect the security of your personal information, we will seek to confirm your identity as part of our processing of any request. Under certain circumstances, we may not fulfill your request, such as where we, in our discretion, deem that your identity has not been reasonably verified or that such information is subject to legal/regulatory, internal audit, record-keeping, or other requirements or legal exceptions such that the request should not reasonably be granted (or should be granted in part). In any event, we will respond to your request within a reasonable timeframe. In order to make such a request of us, please contact us by emailing at tasteslikestroop.com and indicating in the subject line the type of request (e.g., Access, Modification, or Deletion)
     

  • Marketing e-mail preferences:
    You can manage your opt-out preferences for each of our brand’s marketing e-mails by using the unsubscribe link at the bottom of such messages.

    If you no longer want to receive third-party marketing e-mails that you requested through our Services, simply follow the third party’s unsubscribe link or opt-out instructions that should be included each such marketing e-mail from that third party.

    Please note that you cannot opt out of transactional or administrative e-mails (e.g., renewal notifications, orders placed).
     

  • Cookies and other tracking technologies:
    To manage cookies, an individual may have the ability to change their browser settings to (for example): (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies (or certain types of cookies, such as cookies set by third parties). Note that similar controls may exist for other tracking technologies, such as pixels, SDKs, and localStorage. Please check your device or browser settings and related documentation for more information. 

    Further, note that restricting the use of these technologies might negatively impact an individual’s experience using our Services, as some features or offerings may be less personalized or may not work as otherwise intended. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies or other tracking technologies described in this Privacy Policy. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser and device they use. You may also have options within your email client to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain actions with respect to such emails (e.g., URL clickthroughs).
     

  • Online ads:
    To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources at https://www.aboutads.info/choices (or https://www.youronlinechoices.eu/ or https://youradchoices.ca/en/tools for the EEA and Canada, respectively) or the Network Advertising Initiative’s (NAI) online resources at https://www.networkadvertising.org/choices/. You can also opt-out of receiving some interest-based advertisements on mobile apps by visiting https://www.aboutads.info/appchoices. You may also be able to opt-out of some interest-based advertising served by participating mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.

    Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us (or our third-party partners) or on our online services in general. It means that the online ads that you do see from self-regulatory program participants (or other participants that may provide an opt-out mechanism) should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs, or the accuracy of their statements regarding those options or programs. In addition, third parties may still use cookies or other tracking technologies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs/

How do we protect personal information?

We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.  That said, no security system is impenetrable and we cannot guarantee the security of our systems at all times.  Thus, you assume some risk with regard to the security of information you provide through any digital property, including our Services.  To submit reports on vulnerabilities found on our Sites, please contact us as detailed below.

 

What about links to third-party websites or services?

Our Services may provide links to other digital properties that are controlled by third parties. Linked digital properties may have their own privacy notices or policies, which we suggest you review. We are not responsible for the content, usage, terms, or privacy policies of digital properties that we do not own or control.

 

What’s our policy with respect to children’s personal information?

Our Services are not designed or intended for use by children, and we do not knowingly collect or solicit personal information from children under the age of 18 (or the equivalent age of a child in your jurisdiction) on the Services.  If we become aware that we have inadvertently collected personal information from a child under the age of 18 (or the equivalent age of a child in your jurisdiction), we will endeavor to delete any such information promptly.  If you believe that we may have collected information from a child under 18 (or the equivalent age of a child in your jurisdiction), please contact us by email at tasteslikestroop@gmail.com.

Where can I find your region-specific disclosures?

We may choose or be required by law to provide different or additional disclosures about our data privacy practices depending on your state or country of residence:

  • California, Colorado, Connecticut, Nevada, Utah, and Virginia:  If you are a California, Colorado, Connecticut, Nevada, Utah, or Virginia resident, please see the ‘U.S. State Privacy Notice’ section below.

  • European Economic Area, United Kingdom, or Switzerland: If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland, or otherwise engage with our European operations, please see the 'European Privacy Notice' section for additional European-specific privacy information, including what constitutes your personal data, the lawful bases we rely on to process your personal data, and your rights in respect of your personal data.
     

How will we inform you about changes to this privacy policy?

We may update this Privacy Policy periodically to reflect changes to our privacy practices.  If we make any material changes to our privacy practices, we will indicate at the top of the Privacy Policy the date when it was most recently updated and you shall be bound to such changes when accessing the Services that are linked to the updated Privacy Policy.  We may also provide notice of such material changes in other manners at our discretion. We encourage you to periodically review this page for the latest information on our privacy practices.

 

How can you contact us?

If you have questions about this Privacy Policy or about our privacy practices, you may contact us by emailing tasteslikestroop@gmail.com.

If you are a California, Colorado, Connecticut, Utah, or Virginia resident inquiring about your privacy rights under your respective State Privacy Law, please include “U.S. Privacy Rights Request” in the subject line of your email.

If you are a resident of the European Economic Area inquiring about your rights under the General Data Protection Regulation (“GDPR”), please include “GDPR Privacy Rights Request” in the subject line of your email.

U.S. State Privacy Notice

For residents covered under the State Privacy Laws (and Nevada, in the case of the “Notice to Nevada Residents” section only), this U.S. State Privacy Notice supplements the information contained in our Privacy Policy by providing additional information under such laws. The term “State Privacy Laws” means, as applicable, the California Consumer Privacy Act (the “CCPA”), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act.

 

Your Privacy Rights

Depending on your state of residency, you may exercise the following rights under the State Privacy Laws in relation to the personal information about you that we have collected about you (subject to certain limitations under such laws, such as exceptions in the State Privacy Laws or the inability to verify your identity):

 

  • The Right to Access:
    Under the State Privacy Laws, you have the right to obtain confirmation regarding whether we are processing your personal information and to access that personal information. You also have the right to access that personal information in a portable, readily usable format, unless not technically feasible to provide in such a format. 

    Specifically with respect to the CCPA’s right to access, you have the right to request the following: (a) the specific pieces of personal information the business has collected about you and (b) the categories of personal information collected, the sources of collection, the business/commercial purpose for collecting or "selling/sharing" personal information, and the categories of third party to whom the business discloses personal information.
     

  • The Right to Deletion:
    You have the right to request the deletion of PI we have collected from you, subject to certain exceptions under the State Privacy Laws.
     

  • The Right to Correction:
    You have the right to request that inaccuracies in your PI be corrected, taking into account the nature of the personal information and the purposes of the processing of your personal information.
     

  • Opt-Out Rights:
    Under State Privacy Laws, you have the right to opt-out of “sales” and “shares” of personal information, “targeted advertising,” and certain use/disclosure of “sensitive” personal information.

As further described in this Privacy Policy, we disclose the following to our advertising/marketing and analytics partners (e.g., advertisers/agencies, social media networks, adtech partners, customer intelligence firms) for advertising and marketing purposes, including direct marketing: Identifiers, commercial information, geolocation data, internet or other network information, and data that may be considered “sensitive” personal information under certain State Privacy Laws. Please see our “Cookies Settings” link (found in the floating button on the left of the website) to exercise your opt-out rights accordingly.

We do not have actual knowledge of “selling” or “sharing” PI of consumers under sixteen (16) years of age.

Unless otherwise prohibited by the State Privacy Laws, we may need to verify your identity and confirm your residency before processing your request.  In order to verify your identity, we will generally either require the successful authentication of your account or the matching of sufficient information you provide us to the information we maintain about you in our systems.  This process may require us to request additional personal information from you, including, but not limited to, your email address, phone number, or date of last transaction on our Services.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems.  If we cannot comply with a request, we will explain the reasons in our response.

 

Non-Discrimination and Appeals

You have the right to not receive “discriminatory” treatment for exercising the rights discussed in the table above. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

Further, under Colorado, Connecticut, and Virginia’s State Privacy Laws, you may appeal our decision to not take action on your rights request. All appeals should be submitted by contacting us as detailed below, along with a copy of the decision that you are appealing.

 

Authorized Agents

In certain circumstances under the State Privacy Laws, you are permitted to use an authorized agent to submit requests on your behalf (using the mechanisms for submitting requests above), where we can verify the authorized agent’s authority to act on your behalf.

Specifically, under the CCPA, for requests to access, delete, or correct personal information, we require the following for verification purposes:

  • A power of attorney from you or your authorized agent that is valid under the laws of the applicable state where you reside; or

  • Sufficient evidence to show that you have:

    • Provided the authorized agent signed permission to act on your behalf; and

    • Verified your own identity directly with us or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.


For requests to opt-out of “sales,” “shares,” or the processing of your personal information for “targeted advertising” under the State Privacy Laws, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

 

Deidentified Information

Where we process “deidentified information” (as such term is defined under the State Privacy Laws) and are required to keep such information deidentified, we commit to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process we used satisfies the requirements under applicable law.

 

Notice at Collection for California Residents

The following additional disclosures apply to residents covered under the CCPA:

  • Categories/Use of PI:
    In the last 12 months, please see the list below for the categories of personal information we have collected. Further, please see “How do we use personal information?” for the purposes for which such personal information is used.

    • Identifiers:
      Such as your name, email address, date of birth, online identifiers, or other similar identifiers.
       

    • California Customer Records (Cal. Civ. Code § 1798.80(e)):
      Such as birth date, contact information, and payment information.
       

    • Protected Classification Characteristics:
      Such as age and gender.
       

    • Commercial Information:
      Such as payment and purchase history.
       

    • Internet/Network Information:
      Such as device information, logs, and analytics data.
       

    • Geolocation Data:
      Such as location information from your device or generated based on IP address or Wi-Fi.
       

    • Profession/Employment Information:
      Such as your employer, company, or school if your subscription is tied to an employer or school account.
       

    • Other Personal Information:
      Such as information you post on our social media pages or otherwise provide to us.
       

    • Inferences:
      Such as predictions about your interests and preferences.
       

    • Sensitive Personal Information: 
      Such as account username and password or data that may concern your health or race/ethnic origin.
       

  • “Sales” and “Shares”:
    In the previous 12 months, we may have “sold” and “shared” the following categories of personal information to our advertising/marketing and analytics partners for the purposes of advertising/marketing and analytics services, subject to your right to opt-out via our Your Privacy Choices link (found in the website footer): Identifiers, Commercial Information, Geolocation Data, Internet/Network Information, and data that may be considered “sensitive” personal information.
     

  • Data Retention:
    We retain the categories of personal information above as reasonably necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. In many situations, we must obtain all, or a portion, of your personal information to comply with legal obligations, resolve disputes, enforce our agreements, protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.
     

  • Notice of Financial Incentives:
    We may offer you financial incentives for the collection, sale, retention, and use of your PI as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels.  The material aspects of any financial incentive will be explained and described in its program terms.  Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms.  We may add or change incentive programs or their terms by posting notice on the program descriptions and terms linked to above, so check them regularly.
     

  • Each price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, such as by calculating the expense related to the offer, provision, or imposition of the financial incentive or price or service difference or revenue generation or expense related to the sale, collection, or retention of consumers’ personal information.

 

Notice to Nevada Residents

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident.  To exercise your right to opt-out of sales subject to the Nevada Revised Statues, please submit your request by contacting as detailed below.

 

European Privacy Notice

This European Privacy Notice supplements the information contained in our Privacy Policy and applies solely to individuals located in the EEA, the UK, or Switzerland (“you”) and to the Services available in the EEA, UK, and Switzerland that link to this European Privacy Notice:

Controller of your Personal Data

The controller of your personal data under this European Privacy Notice is Stroop which can be contacted at tasteslikestroop@gmail.com

Legal Basis for Using Personal Data

We process your personal data only if we have a legal basis to do so, including:

  • to comply with our legal and regulatory obligations;

  • for the performance of our contract with you or to take steps at your request before entering into a contract;

  • for our legitimate interests or those of a third party;

  • where you have given consent to our specific use.

 

The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is further explained below.

 

Purposes for which we will process the information & legal basis for such processing

  • To provide products and services you request: It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between us (or take necessary steps relating thereto).

  • To respond to requests, questions, and comments, and provide other types of user support: It is necessary for us to respond to requests, questions, and comments, and provide other types of user support in order to take steps at your request or according to the applicable contract between us.

  • To offer you products and services in marketing communications, or direct you to portions of this Site or other websites, that we believe may interest you: We may send electronic marketing communications to you if you have consented to these communications. It is in our legitimate interest to market out products and services to you by other means and to direct you to portions of this Site or other websites that we believe may interest you. We consider this use to be proportionate and will not be prejudicial or detrimental to your rights and freedoms.

  • To communicate about, and administer your participation in, events, programs, contests, and other offers or promotions: We will send electronic communications to you if you have consented to these communications, where such consent is required by applicable law. With respect to other communications, it is in our legitimate interest to communicate to you and administer your participation in, our events, programs, contests, and other offers or promotions. We consider this use to be proportionate and will not be prejudicial or detrimental to your rights and freedoms.

  • To carry out, evaluate, and improve our business (which may include developing new features for the Services; analyzing and enhancing the user experience on the Services; optimizing and assessing the effectiveness of our marketing and advertising; and managing our communications): It is in our legitimate interests to process your personal data to carry out these activities. We consider this use to be proportionate and will not be prejudicial or detrimental to your rights and freedoms.

  • To perform data analytics regarding usage of the Services (including market and customer research, trend analysis, financial analysis, and pseudonymization or anonymization of personal data): It is in our legitimate interests to process your personal data to carry out these activities. We consider this use to be proportionate and will not be prejudicial or detrimental to you.

  • To serve advertising, content, and offers to you based on your interests and online activities, from us or third parties: We will serve you advertising, content and offers to you based on your interests and online activities if you have consented to this processing.

  • To enable our affiliates or service providers to perform certain activities on our behalf: It is necessary for us to process your personal data in this manner in order to deliver the services and process transactions according to the applicable contract between us. It is also in our legitimate interest to enable our service providers and affiliates to perform certain activities on our behalf. We consider this use to be proportionate and will not be prejudicial or detrimental to your rights and freedoms.

  • To notify you of any changes to the Services that may affect you: It is necessary for us to process your personal data in order to deliver the services and process transactions according to the applicable contract between us.

  • If we are required to do so by law, regulation, or legal process (such as a court order or subpoena); in response to requests from government agencies, such as law enforcement authorities, including to meet national security requirements; if we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity; and in the event we sell or transfer all or a portion of our business or assets (including a reorganization, dissolution, or liquidation).  In such an event, we will seek to provide you with commercially reasonable notice, e.g., via email and/or notice on our Sites, of any change in ownership, incompatible new uses of your personal data, and choices you may have regarding your personal data:  We conduct this processing to comply with our legal obligations and to protect the public interest.

  • Guard against, identify, and prevent fraud and other criminal activity, claims, and other liabilities; and comply with applicable legal requirements, law enforcement requests, and our company policies:  We conduct this processing to comply with our legal obligations and to protect the public interest.

International Transfers

Some of our processing of your data will involve transferring your data outside the EEA, UK, or Switzerland. Some of our external third-party service providers are also based outside of Europe and their processing of your personal data will involve a transfer of data outside of Europe. This includes the United States. Where personal data is transferred to, stored in, or processed in a country not determined by the European Commission as providing adequate levels of protection for personal data, we take steps to provide appropriate safeguards to protect your personal data, including, when appropriate, entering into standard contractual clauses approved by the European Commission.

 

Retention of Personal Data

We will retain your personal data only for as long as necessary for the purposes it was retained, such as to enable you to use the Services. In some instances, we may retain data for longer periods in order to comply with applicable laws (including those regarding document retention), resolve disputes with any parties, and otherwise as necessary to allow us to conduct our business.

 

Data Subject Rights

If you are located in the EEA, the UK, or Switzerland, you have the following rights in respect of your personal data that we hold:

 

  • Right of access:
    You have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information.
     

  • Right to correction:
    You have the right to have your personal data corrected, as permitted by law.
     

  • Right to erasure:
    You have the right to ask us to delete your personal data, as permitted by law.
     

  • Right to withdraw consent:
    You have the right to withdraw consent that you have provided.
     

  • Right to lodge a complaint with a supervisory authority:
    You have the right to lodge a complaint with a supervisory authority in the member state of your habitual residence.
     

  • Right to restriction of processing:
    You have the right to request the limiting of our processing under limited circumstances.
     

  • Right to data portability:
    You have the right to receive the personal data that you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
     

  • Right to object:
    You have the right to object to our processing of your personal data, as permitted by law, under limited circumstances.
     

To exercise any of these rights, please submit a request through the European Rights Request Form. Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. 

 

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

How to Contact Us

All feedback, questions, and comments  in connection with our privacy practices and our privacy policies should be directed to: tasteslikestroop@gmail.com.

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