Privacy Policy

Effective Date: November 20, 2018

POPSUGAR Inc., its affiliates and its subsidiaries (collectively, "POPSUGAR", "us" or "we") take your privacy seriously and have developed this Privacy Policy ("Privacy Policy") to explain what we collect from our users ("users" or "you") and how we use and share this information. This Privacy Policy applies to your use of our websites, mobile websites, mobile applications, and any related services (please see our Terms of Service) (collectively, the "Services").

We may change this policy from time to time and will notify you by revising the date at the top of the Privacy Policy. Please review this Privacy Policy whenever you access the Services to stay informed of our practices.

1. WHAT INFORMATION WE COLLECT OR RECEIVE

Personal Information

We may collect "personally identifiable" information, which means information that might reasonably be used to specifically identify you and may include information such as the following (collectively, "Personal Information"):

• Contact information such as your name, postal address, email address, phone number and/or mobile number;
• Age and/or date of birth;
• User name and password; and
• Location data that describes the precise geographic location of your device ("Precise Location Data").

Other Information

We also collect "Other Information" from you or other sources which is information not considered Personal Information. Other Information may include, but is not limited to, information such as:

• Article preferences, topics of interest or other content preferences by using "Like" or "Dislike" settings or creating lists;
• Display name, which in some cases may be different from your user name;
• Photos, for example, account photos and photos you submit to our Twinning Service;
• "About" or other biographical information you provide and/or post on the Services;
• Comments or other information you post on the Services, which may also contain Personal Information if such information identifies you;
• Links to your social media accounts and websites;
• Browsing history, including the pages of the Services you visited and third party pages or services you visited other than the Services;
• Device type, settings and software used;
• Device identification number ("Device ID"), which is a distinctive number associated with a mobile device;
• "Advertising ID", which is a unique, user-resettable identification number for advertising associated with a device (e.g. iOS uses the Identifier for Advertising and Android uses Google Advertising ID);
• Internet Protocol address ("IP Address"), which is a unique string of numbers automatically assigned to device whenever you access the Internet (but which may be identical to the IP Address of other users on the same network);
• Log files, which may include IP Addresses, browser type, internet service provider referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links;
• "Web Beacons", which are electronic files that allow a website to count users who have visited that page or to access certain Cookies (as defined below under HOW WE COLLECT OR RECEIVE INFORMATION);
• "Pixels" or "Pixel Tags", also known as clear GIFs, beacons, spotlight tags or web bugs, are a method for passing information from the user's computer to a third party website;
• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user's computer or device derived from the IP address of such computer or device;
• "Local Shared Objects", which are pieces of data that websites may store on a user's computer, including Brower Cookies and Local Storage; and
• Information collected through the use of Cookies, eTags, Javascript, Pixel Tags, Device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services and third party websites, applications, platforms and other media channels, and (ii) your interaction with emails including the content and ads (collectively, "Interaction Data").

All Personal Information and Other Information that we hold about you is referred to in this Privacy Policy collectively and generally as "User Information."

This Privacy Policy does not apply to the practices of any other company or individual that is not owned or controlled by POPSUGAR.

2. HOW WE COLLECT OR RECEIVE INFORMATION

We collect User Information across our Services, including as follows:

• When you register for our Services (for example, name, username, display name, password, country or state of location, zip code, postal mail address and email address);
• If you sign up for an email subscription on our Services, we collect your email address and may also collect other information about your subscription preferences and interests;
• For some of our Services, you may be asked to provide your mobile phone number in order to receive text messages containing information you have requested and other information that we think may be of interest to you;
• When you view or interact with our Services, we may collect certain data, including IP Address, language setting, operating system type, page you requested, Advertising ID, user agent, and time stamp;
• When you use the Services, we collect information about your search and click activity;
• We may collect or receive information about you when you sign up for a sweepstakes, contest or other giveaway or promotion ("Promotions") offered by us or our partners;
• We may collect your user-generated content (for example, photos that you take or upload, comments that you provide or workout routines that you create, or URL links);
• The POPSUGAR What The Face app includes the TrueDepth API technology that has face recognition and the ability to collect information used to identify you, but we do not use those technologies to gather any data in any way (incidental or otherwise) in this app.
• When you make a purchase through our Services, we or our vendors may also collect your information as set forth below under WHAT INFORMATION WE SHARE WITH THIRD PARTIES;
• When you send an email to us, we will receive your email address and other information associated with your request;
• Your Personal Information may be provided by other users of the Services (for example, when another user gives you a gift subscription of our "Must Have" box Service and provides your email in connection with the gift);
• If you use a third party connection or log-in (such as Facebook Connect or Google) in connection with the Services, we may receive your name, email address and/or profile photo for those third party services or other information available about you or collected from you on those services; and
• We may also supplement the User Information we collect from you with information from third parties, including third party vendors, affiliate network operators, referral sources, social networking sites or services (such as Facebook), and publicly-available sources.

Cookies and Web Beacons

Some of the User Information is collected on the Services through the use of Cookies and/or Web Beacons. "Cookies" are small data file identifiers that are transferred to your computer or mobile web browser that allow us, and third parties with whom we partner, to recognize your browser or mobile device and transfer information about you and your use of our Services. For example, Cookies that we use tell us how many times you have visited one of our websites, your search preferences, and if you have clicked on an advertisement that has been displayed to you. We use "persistent" Cookies to save your login information for future logins to the Services. We also use "session ID" Cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by users and web traffic routing on the Services. Unlike persistent Cookies, session ID Cookies are deleted from your computer when you log off from a Service and close your browser.

We (and third parties with whom we partner) may also deliver a file known as a web beacon, pixel or pixel tag (i.e., "Web Beacons") to you through our Services. Web Beacons are small, invisible graphic images that may be used on the Services interface or in emails relating to the Services to collect certain information and monitor user activity on the Services interface, such as to count visits, access Cookies, understand usage effectiveness and to determine if an email has been opened and acted upon. "Pixels" or "Pixel Tags" also known as clear GIFs, beacons, spotlight, tags or web bugs, are a method for passing information from the user's computer to a third party website. We (and third parties with whom we partner) may deliver Web Beacons or Pixel Tags to you through our Services. Web Beacons allow ad networks, marketing partners and other service providers that we use to provide anonymized, aggregated auditing, research and reporting for us, for advertisers and our other partners. Web Beacons also enable ad networks and other partners to track your behavior for their own analysis and use, and to serve targeted advertisements to you when you visit other websites or platforms. These Web Beacons enable third party companies to view, edit, or set their own Cookies when you visit the Services, just as if you had visited a web page from their site.

3. HOW WE USE YOUR INFORMATION

User Information is used to provide Services to you by POPSUGAR and its partners, which includes using such information to:

• Allow you to set up an account and profile and log into your account on the Services and to access certain parts of the Services through such account;
• Allow you to share certain information about yourself with other users through your account profile;
• For our POPSUGAR Voices or Influencer platforms, to determine what assignments or projects are a good fit for your skills and interests and to process payments for your services if you are selected for a paid assignment;
• Personalize and improve the Services;
• Connect you across multiple devices or platforms where you are accessing our content;
• Customize the Services to provide advertisements, content, features or recommendations on the Services or on other platforms (for example, social media platforms) that match your interests;
• Send you notices, updates and other administrative messages;
• Process transactions and send you related information;
• Send emails or newsletters to you, which may also offer or advertise POPSUGAR or third party products and/or services;
• Administer or communicate with you about Promotions;
• Link or combine information we receive from third parties to help provide you with better service;
• Detect, investigate and/or prevent fraudulent, unauthorized, or illegal activity;
• Analyze and monitor how our users utilize the Services; and
• Carry out other purposes described in this Privacy Policy.

We may use your User Information to contact or communicate with you, for example, by email, postal mail, notices on our websites or applications, newsletters or other means available through the Services, including push notifications and mobile text messages. Such communications may contain messages of a commercial or non-commercial nature, including but not limited to, messages necessary to provide the Services to you, responses to an inquiry that you submitted, marketing and promotional messages for our Services or the products and/or services of our partners and advertisers, messages sent for administrative purposes related to the Services, and other communications as needed to carry out other purposes described in this Privacy Policy.

When you receive email messages or newsletters from us, we may use Web Beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you more focused email communications or other information, and/or aggregate such data with other data we collect for some or all of the purposes outlined in this Privacy Policy.

We and our partners use Cookies and other tracking technologies to administer the Services, analyze trends, track users' movements around the Services and on third party sites, devices and applications, and to gather demographic information about our user base.

We may also receive certain data (on an individual and/or aggregated basis) collected by our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) through the use of Pixel Tags, e-tags, IP Addresses, Local Shared Objects, Local Storage, and Browser cookies, which allows us to:

• Analyze trends across our user base;
• Collect and store information such as user settings;
• Supplement our server logs and other methods of traffic and response measurement;
• Track users' location and movements around the Services; and
• Improve our understanding of traffic on the Services, visitor behavior, and responses to advertising and promotional campaigns.

POPSUGAR also works with third parties to provide analytics information regarding your usage of our Services or to help us track the advertisements that are delivered to you to determine the effectiveness of advertising on our Services. We may also link this information to User Information.

4. WHAT INFORMATION WE SHARE WITH THIRD PARTIES

Advertising and marketing

Certain third party vendors and partners authorized by POPSUGAR (including, but not limited to, advertisers, advertising agencies, ad networks, ad measurement providers, and other marketing and advertising service providers and partners) ("Advertisers") may collect information about you on the Services in order to provide you with relevant advertising on the Services and on other websites, platforms and media channels, and to analyze the performance of advertising campaigns. These Advertisers may use tracking technologies such as Cookies, Web Beacons, and other similar technologies, and may collect many different kinds of data, such as your IP Address, Device ID, Advertising ID and Precise Location Data where made available by your mobile device. The specific Advertisers we work with are subject to change at any time. For a list of some of the applicable providers or for more details on opting out of tracking for advertising purposes, go to our Cookie Consent Tool by clicking on the button in the lower right corner of your screen labeled "Cookie Consent". The use of tracking technologies by these third parties is subject to their own privacy policies.

To opt out of collection of your information by Nielsen, or to obtain information about the technologies they use or their own privacy policies, please visit the Nielsen consumer opt out page located here.

We may also sell or transfer Interaction Data to certain Advertisers who will use this data to serve ads that they believe are relevant to your interests. Some of these third parties may combine the Interaction Data with their own data about you to form a more detailed picture. We may also share your information with Advertisers for the purpose of allowing them or their clients to send you marketing communications related to your use of the Services, their services or programs featured and/or advertised on the Services (e.g., through ads or Promotions), or their products, services and/or programs generally.

Our third party vendors and partners use your User Information to display ads on both the Services and on third party websites, applications, platforms and other media channels (collectively, "Channels"). For example, if you read content about a particular subject on the Services, we may use Cookies from a vendor to later serve you an advertisement for a particular product or service related to the viewed content. These third party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel. Likewise, third party vendors may serve you advertisements when you visit the Services based on your interaction with the Services and other Channels.

Some of our Services may use Facebook and Instagram features and tools, including Pixel Tags, which send data regarding your use of the Services to Facebook and/or Instagram for the purpose of tracking your interaction with the Services and with our brand on Facebook and Instagram, and to create custom audiences on the Facebook and/or Instagram platforms. Facebook and Instagram link the data collected on our Services with your account on their platforms and we and/or our Advertisers may use that data to serve you with advertisements both on and off of Facebook and Instagram.

We may provide certain Advertisers with information regarding your interactions with our emails and newsletters or as to whether your information matches certain information held by the Advertiser and/or their customers. Those Advertisers may combine this data with information they collect for their own marketing purposes and in turn, may provide this information to their customers for their customers' marketing purposes.

In order to help us sell advertising on the Services and otherwise publicize POPSUGAR and its products and services, we may share aggregate statistics that describe our online audience. Those statistics are often based on the information you provide when you subscribe, register, or browse the Services and describe, among other things, the demographics of our visitors.

Third party service providers

We employ or utilize the services of other third party vendors, consultants and service providers who need access to your User Information (such as your name, address, email, or other identifiers) in order to enable them to perform services on our behalf or to provide us with additional information necessary to provide you one of our Services to you. We use third party vendors for a variety of services across our Services, such as email message deployment, email address validation, subscription fulfillment, research, statistical analysis, cross-device user tracking, data and website hosting, marketing, advertising, and other data and transaction processing.

We also engage third party service providers for the purpose of processing payments for subscriptions, to fulfill your orders for product purchases, to honor your request to be removed from promotional mailings, and to monitor, analyze and prevent fraudulent traffic or other suspicious activities on our Services or on other services. For our Voices and Influencer platforms, we may also provide your User Information to third party processors in order to process payments for services if you are selected for a paid assignment under those platforms.

In addition to receiving your User Information from us, our service providers may also:

• Collect information directly from you and/or your device, such as your IP Address, Device ID, Advertising ID, and information about your browser or operating system;
• Combine User Information about you received from POPSUGAR with information about you from other sites or services; and/or
• Place or recognize a unique Cookie or other tracking mechanism on your browser.

Third party partners and websites

Our third party partners may sell items or provide services to you through our Services (either alone or jointly with us). In some of these cases, you will be routed through to the third party's website, where you will complete the purchase. When you make a purchase or activate the partner's service (for example, through our POPSUGAR Must Have Service) we may share your Personal Information, such as an email address, with that partner, who may use this Personal Information in accordance with its own privacy policy. Please note that we are not responsible for any applicable third party terms or policies and you should review them carefully.

Social plug-ins and embeds

We may use social plugins on our Services, for instance plugins of the social networks such as Facebook, Twitter, Google+, Pinterest and Tumblr, and may feature icons, like the "thumbs up" icon or text like "Recommend", "Like" or "Comment". We also feature certain embedded content on our Services such as text and video content embedded from social networks and other third party platforms including, but not limited to, Facebook, Twitter, YouTube, Pinterest, and Vimeo. Your browser may create a connection to the servers of such social networks and other third parties and/or transmit data to such third party servers when you view a page on our Services. This Privacy Policy does not cover the practices of these third party social networks.

User profiles and submissions

Certain User Information from your profile such as a your user name, display name, biographical information, or any comments or video or image content that you have uploaded to the Services may be displayed to other users to facilitate user interaction within the Service or address your request for Services. In some applications, information you share in your profile will be publicly available to other users. For example, for our Binge service, certain profile information and a link to your complete profile may be found in the Binge public search feature. You may opt out of being included in the public search feature on Binge by turning off this setting in the profile tab of the Binge application. For our POPSUGAR Voices and Influencer platforms, User Information from your profile may be shared with third parties including advertisers in connection with an advertising campaign, which may include publicly-available metrics related to your social media channels and a description of your blog or other content you have created in the past.

Third party offers

In connection with some advertising campaigns or otherwise in connection with the Services, We may create and/or distribute custom digital promotional cards that you can elect to save into your digital wallet on your mobile device (examples of such digital wallets include Apple Wallet and Android Pay), which may feature a coupon, rebate, promotional discount or other offer from an advertiser or sponsor and/or POPSUGAR (each an "Offer"). When you engage with, download, share, or redeem an Offer, certain information about you may be collected by our third party advertising partners, including, but not limited to, data about your device such as user agent, operating system, advertising identifiers, Device IDs, Precise Location Data, and other data about your interaction with such Offer. Certain information may also be collected by or shared with third party providers who offer mobile wallet services on your device (for example, Apple for Apple Wallet or Google for Android Pay). The collection and use of such data by these third parties is subject to their respective terms and privacy policies. POPSUGAR is not responsible for any applicable third-party terms or policies and you should review them carefully. To opt out of such third party Offers, see the section below entitled HOW YOU CAN CHANGE OR CONTROL WHAT IS COLLECTED.

Promotions

We may collect and share User Information you provide in connection with a Promotion with an advertiser who sponsors the Promotion and/or a service provider may collect your information in connection with such Promotion on our behalf. In the event that your User Information is shared with a sponsor or other third party, it would also be subject to the sponsor's or such other third party's privacy policy, and it may be used by us, the sponsor, and/or such other third parties for follow up or other marketing purposes. For all Promotions, please read the official rules and any other terms and conditions for that Promotion carefully before you submit your User Information or otherwise participate in the Promotion.

Text message services

By signing up for our text messages services such as POPSUGAR Must Have It or Gazelle, you expressly agree that we may share your mobile phone number and the contents of any message you send or receive through such Service with our third party partner, Twilio. For more information regarding how Twilio may store or use your information, please review Twilio's Privacy Policy.

Payment card information

To use certain aspects of our Services, such as subscribing to our Must Have Box Service or participating in our Must Have It Service, we may require you to submit credit or debit card account information. By submitting your credit or debit card account information through the Services, you expressly consent to the sharing of this information with third party retailers, subscription and billing processors, and payment processors.

We may use Stripe to collect your credit or debit card account information and/or process such payments with our financial institutions. Stripe may store your credit or debit card account information so you can use our Services in the future. We do not have access to your complete credit or debit card account information, store your credit or debit card account information, or have direct control over or responsibility for your credit or debit card account information. We cannot guarantee that transmissions of your credit or debit card account information or personal information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third party service providers. Please see the Stripe Terms and Conditions and the Stripe Privacy Policy.

We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third party access, or other causes beyond our control.

Twinning

For our Twinning Service, we collect photos you submit and may provide them to our third party service providers for analysis and matching with similar-looking celebrities or public figures. When you submit a photo to Twinning, we post a composite image of your photo and your celebrity look-a-likes on a public URL for you to reference and share with your friends. While we only provide this unique URL to you, the URL is public and may be viewed by anyone who has the link. You can request removal of any unique URL created in connection with your photos through Twinning by contacting us at community@popsugar.com.

International partners

On some occasions, we may host websites that are operated by international partners. We may share your User Information with these partners in order for them to provide the Services on those international websites. This Privacy Policy does not apply to the practices of our international partners and each international website is subject to its own posted privacy policy.

Business transfers

We may share your User Information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where User Information may be disclosed or transferred as one of our business assets.

Enforcement of terms and policies

We may share your information to enforce or apply our Privacy Policy, Terms of Service, or our other policies or agreements.

Protection of POPSUGAR and others

We may access, read, preserve, and disclose any User Information where we reasonably believe a disclosure is necessary to comply with law or court order; or protect the rights, property, or safety of POPSUGAR, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

With your consent

We may share your User Information in other circumstances with your consent, for example when you have chosen to link an account with our Services with a social media network like Facebook or Google.

5. HOW YOU CAN CHANGE OR CONTROL WHAT IS COLLECTED

Changing your account settings

You may add, update or delete information through your user account settings, which limits the ability of other users to see the information in your user profile. The information you can view, update, or delete may be different depending on which area of the Services you are using and may also change as the Services change.

If you have any trouble accessing, correcting or deleting any of your information, or would like to make a request about whether POPSUGAR holds any of your Personal Information, please contact us at community@popsugar.com and we will respond to your request within a reasonable timeframe.

Cookies

You can usually instruct your browser by changing its settings to stop accepting Cookies or to prompt you before accepting a Cookie from our websites that you visit. If you choose to disable Cookies, you may not be able to use all portions of the Services or all functionality of the Services. For more details on opting out of tracking for advertising purposes, go to our Cookie Consent Tool by clicking on the button in the lower right corner of your screen labeled "Cookie Consent".

Precise location data

You may opt out of having your Precise Location Data collected us at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).

Newsletter and email subscriptions

If you do not want to receive email or other mail from us, please indicate your preference by changing your account settings, contacting us at community@popsugar.com, or by clicking the "unsubscribe" link in an email we send to you. If you do not wish to receive email or other mail from Advertisers, or other third party partners, please refer to the applicable third party privacy policy and request an opt-out directly from the Advertiser or other third party partner.

Deactivating Your Account

You can always choose not to disclose information to us or delete information, but keep in mind some information may be needed to register with us or to take advantage of some of our special features. You may request deactivation of your account by contacting us at community@popsugar.com.

De-linking your account

In order to de-link your POPSUGAR account from an account on another service such as a social media account, you must adjust your account settings with the third party application. For example, if you want to de-link your Facebook account with POPSUGAR, you must de-link your accounts in both your POPSUGAR account settings and in your Facebook application settings.

Push notifications

You may adjust the "Settings" on your mobile device settings (or within the "profile" tab of certain applications) to disable push notifications for any of our mobile applications for which you would like to stop receiving such notifications. You may adjust the "Notification" settings usually found in your browser "Preferences" or "Settings" to block or remove certain browser-based push notifications.

Third party offers

To remove Offers (described in the section above entitled "WHAT INFORMATION WE SHARE WITH THIRD PARTIES") from your mobile device, go into your mobile wallet and delete or remove the applicable Offer. When you remove the Offer from your mobile wallet, your data will no longer be collected by POPSUGAR or its partners in connection with such Offer. To opt out of the collection of Precise Location Data by third parties in connection with Offers in your mobile wallet, go to the privacy settings on your device and turn off location data collection for the mobile wallet.

Text messages

If you no longer wish to receive text messages from any of our text message services (such as our Must Have It Service or Gazelle Service), you can reply "STOP" to any text message sent by us through such Service. For our Must Have It Service, if you have a POPSUGAR account linked to the phone number you provided for the Must Have It Service, you can also visit the "Account Settings" page in your Must Have account and change the Must Have It Phone Number settings from "on" to "off."

California residents

In accordance with the California Online Privacy Protection Act (see California Civil Code Sections 1798.83-1798.84), California residents are entitled to ask us for a notice identifying the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and wish to make such a request, please submit your request in writing to community@popsugar.com.

Do Not Track

We currently do not participate in any "Do Not Track" frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our website.

6. OTHER USEFUL INFORMATION REGARDING YOUR PRIVACY

Security

We use commercially reasonable safeguards to preserve the integrity and security of information collected and maintained through our Services. However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed by unauthorized persons or hardware or software failure. You are ultimately responsible for the security of your email address and password.

Children

The Services are not directed to children under 13, and we do not knowingly collect or solicit personally identifiable information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us. If a parent or guardian becomes aware that their child has provided us with Personal Information without their consent, please contact us at community@popsugar.com.

International transfer

Your User Information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, POPSUGAR transfers personal information to the United States and processes it there. By submitting such information, you consent to that transfer.

Data retention

The time period for which we keep information varies according to the information's use. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

7. HOW TO CONTACT POPSUGAR

If you have any questions or concerns regarding this Privacy Policy, please send us a detailed message to community@popsugar.com. We can also be contacted at the following address:

POPSUGAR Inc.
111 Sutter Street, 16th Floor
San Francisco, California, 94104
United States