We collect personal data from the following sources:
Any references in this policy to “you” or “your” should be interpreted in the context in which the information is processed. Personal data means any information that relates to an identified or identifiable living individual.
Our legal bases for processing your personal data include your consent, fulfilment of a contractual obligation, and where we have a legitimate interest to process your personal data, provided that our interests do not outweigh your individual rights and freedoms.
Our legitimate interests include:
Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this policy.
Protecting and defending our rights and properties, including intellectual property.
Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities.
Improving your experiences with our products and services, understanding and improving our website, user experience, and customer relationships.
We collect personal data that you provide to us directly, as well as information provided by your browser or device when you visit our website. We also collect personal data via the portals connected to our site.
We collect personal data only when you submit it to us, such as when you:
The Personal Data you submit may include, but is not limited to, your name, postal address (including billing and shipping addresses), telephone number, mobile number, email address, gender, username, or profile picture.
To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, business partners, and the third party provider of your subscription.
The Personal Data we receive from third parties may include your name, contact information, or relationships with various product and service providers. For example, if you access a Smile Avenue site through a social media service, the information we collect may also include your user ID, username, profile picture, or email address.
When you access Smile Avenue through social media services or connect Smile Avenue to social media services, you are authorizing Smile Avenue to collect, store, and use such information and content in accordance with this Privacy Notice. The information we obtain depends on your privacy settings on the applicable social media service.
“Other Information” is any information that is not intended to reveal your specific identity to us, such as:
We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your experience, professional licensing, and other information), live event accommodations, and interests.
We may receive Other Information about you from third parties, including demographic data, social media account number, information about your interests, and information about your activities on other websites.
Our services use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies, please see our Cookies Policy.
Smile Avenue may be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features.
Some of these third party sites may be co-branded with a Smile Avenue logo, even though they are not operated or maintained by us. Smile Avenue is not responsible for the privacy practices of such third parties, and once you leave a Smile Avenue site or click an advertisement, you should check the applicable third party privacy notice.
We will not share or sell your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign.
We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.
All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
If you have questions about this Privacy Notice or how we or our service providers handle your Personal Data, please contact our Internal Controls Manager and Privacy Officer:
We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, depending on where you are located you can contact a supervisory authority or your state’s attorney general.
Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.
