PRIVACY POLICY

ECOMGRADUATES LLC

PRIVACY POLICY
Effective as of August 10, 2023

 

EcomGraduates LLC (“EcomGraduates”, “we,” “us,” or “our”) created this privacy policy (“Privacy Policy”) because we care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of EcomGraduates relating to its website, www.ecomgraduates.com (the “Website”).

 

By visiting our Website and/or purchasing any products from us, you are agreeing to the terms of this Privacy Policy and our Website Terms and Conditions located at www.ecomgraduates.com/terms-of-use. We may from time to time change this Privacy Policy, so please check back periodically.

 

WHAT INFORMATION WE COLLECT?

 

We collect personal information that you provide to us or consent to when you use the Website, express an interest in obtaining information about us or our products and services, when you participate in activities on the Website or otherwise when you contact us.

 

Personal Information

 

We may request personal information from you (“User”) (hereinafter referred to as “Personal Information”). For example:

 

• If you decide to purchase any products or services from the Website, we will collect Personal Information about you. EcomGraduates uses Shopify, Inc. and its affiliates, an online eCommerce platform to support customer purchasing of products from the Website. Shopify, Inc., and its affiliates, employs a variety of security and risk management technologies to facilitate secure online transactions and to protect your information. Any payments are processed by payment processing providers that are PCI/DSS-compliant. If you purchase any goods or services through our Website, your credit card information will be transferred to Shopify, Inc. and its affiliates for processing. You can find more information about Shopify Inc. at https://www.shopify.com and https://www.shopify.com/legal/privacy. 

 

• If you enroll in any and all accounts through the Website, we may ask that you provide us with certain personal information, including, your first name, last name, email address, social media handles and/or user name(s), credit card number, expiration date, mailing address, and telephone number.

 

• If you post to our discussion forums or blogs that may exist from time to time, we will ask that you provide us with your name, e-mail address, and password.

 

• If you want to enter any sweepstakes, contests or promotions sponsored by us or by one of our business partners, we will need your name, e-mail address and other information as may be required by the rules of the specific contest.

 

• If you choose to participate in a survey conducted by us or by one of our business partners, we may ask for your name, e-mail address and other information as may be required by the particular survey.

 

• If you report a problem or submit a review, we will ask that you provide your name, e-mail address, address, and phone number. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.

 

If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as soon as commercially practicable. If you believe that a User under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at  support@ecomgraduates.com.

 

Usage Information

 

Like most websites, we may collect information through commonly used information-gathering tools, including without limitation, cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. We may also track your usage, location (and location-based services), mobile device data (including geo-location services), and certain third-party website permissions (including standard Meta (facebook.com/Instagram.com) basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.

 

The purpose of cookies and other commonly used information gathering tools is to record information that identifies your computer, to track your use of our Website, and to collect certain basic information about you and your surfing habits, whenever you visit our Website. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, mobile device you use, mobile device unique ID, IP address of the mobile device, and similar information concerning your use of the Website (the “Usage Information”).

 

By agreeing to these terms and/or using, navigating or otherwise engaging with the Website, you hereby consent to the use of these cookies and other gathering tools to collect your Usage Information. You can block or delete these cookies by changing the browser settings on your computer or mobile device. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Website, but may not be able to use some areas of the Website. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers.

 

If you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.

 

HOW DO WE USE YOUR INFORMATION?

 

We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you and for general business purposes. We will use your Personal Information and Usage Information collected through the Website for the following purposes:

 

• To provide you with the goods or services you have paid for on our Website (including order fulfillment, management, service and support);

• To facilitate account creation and logon process. Specifically, if you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of our services;

• To post testimonials on our Website provided by you that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at support@ecomgraduates.com and be sure to include your name, testimonial location, and contact information;

• To send you marketing and promotional communications via our and/or our third-party marketing partners for marketing purposes. For example, when expressing an interest in obtaining information about us or our services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time;

• To request feedback from you about our Website and services;

• To enable user-to-user communications, subject to your prior consent;

• To manage user accounts and functionality;

• To protect our services, products and Website (for example, fraud monitoring and prevention).

• To enforce our terms, conditions and policies, to comply with legal and regulatory requirements or in connection with our Website, goods and services;

• To provide you information on the products you have purchased through the Website;

• To identify you when you sign into your account;

• To respond to your requests and to provide you with information;

• To respond to your inquiries and contact you about changes to the Website;

• To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving, and for billing and collection purposes;

• To send you information we think you may find useful or that you have requested from us;

• To enhance and improve the Website or the Service, such as through personalized features and content;

• To analyze the use of the Website and the people visiting to improve our content and Website;

• To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;

• For any other purposes disclosed at the time the information is collected or to which you consent; and

• As otherwise specifically described in this Privacy Policy, otherwise agreed to by you, or for other business purposes we deem in the best interest of the Website.

 

HOW DO WE PROTECT YOUR INFORMATION?

 

It is important to remember that whenever you voluntarily disclose Personal Information, such information can be collected and used by others. If you transmit or post Personal Information on-line that is accessible to others, you will not be able to control how that information is used by others. When we receive the transmitted information, we take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Unfortunately, notwithstanding any of the steps taken by us, it is not possible to guarantee the security and integrity of data transmitted over the Internet. We cannot guarantee and do not warrant the security of our databases, nor the guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. All such transmission of information is at your own risk. Moreover, though we are committed to having our Website comply with this Privacy Policy, you are ultimately responsible for maintaining the secrecy of your Personal Information. If you are careless with your password, or you decide to share your password with third parties, you must be aware of the risk that such third parties will have access to all your Personal Information.

 

If you do not wish for us, any of our third-party vendors, or other government agency to view your information, DO NOT PROVIDE US WITH SUCH PERSONAL INFORMATION BY PURCHASING ANY GOODS OR SERVICES PROVIDED BY ECOMGRADUATES FROM TIME TO TIME OR OTHERWISE USE THE WEBSITE.

 

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

 

EcomGraduates will retain your Personal Information only for as long as is necessary for the purpose set forth in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

 

EcomGraduates will also retain Usage Information for internal analysis purposes. Usage Information is generally retained for a shorter period of time, except when this data is used to strengthen security or improve the functionality of our products, services or Website, or we are legally obligated to retain this data for longer periods.

 

WHO DO WE DISCLOSE YOUR PERSONAL INFORATION TO?

 

Subject to the following paragraphs, we do not disclose your Personal Information to third parties for their direct marketing purposes unless you have agreed to such disclosure.

 

We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information. Some third-party programs include Google and Facebook.

 

Third parties that have links on our Website may collect personally identifiable information about you. We are not responsible for the privacy policies or practices of such websites and the practices of these websites are not governed by this Privacy Policy. If you have questions about the privacy policies or practices of a third-party website, you should contact the website administrator or webmaster of the specific website. We may from time to time partner with other companies to offer co-branded goods or services as well as sweepstakes, contests and promotions. Any information that you provide in connection with the co-branded services or any jointly sponsored sweepstakes, contests or promotions will become the joint property of EcomGraduates and its business partners. We will maintain your information in accordance with the terms of this Privacy Policy. However, this Privacy Policy does not govern the privacy policies and practices of our business partners. If you have questions about the privacy policies or practices of our business partners, you should contact them directly.

 

We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including without limitation, in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of this Website, or anyone else that could be harmed by such activities.

 

DO WE SELL OR RENT YOUR PERSONALLY IDENTIFIABLE INFORMATION?

 

No, as a general rule, we do not sell or rent your Personal Information to anyone. If and whenever we intend to share your Personal Information with a third party (other than to a business partner as provided herein), you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer. However, we may from time to time rent or sell demographic information in the aggregate that does not contain your Personal Information or otherwise sell or rent your information provided it is anonymized without specific reference to you.

 

We may share all or part of your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of EcomGraduates LLC’s business or assets to such business entity (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor business entity to honor the terms of this Privacy Policy.

 

HOW CAN YOU UPDATE, CORRECT, OR DELETE YOUR PERSONALLY IDENTIFIABLE INFORMATION?

 

Information for California Residents

 

CALIFORNIA RESIDENTS (California-Specific description of privacy rights – under the California Consumer Privacy Act - CCPA). This section fully incorporates all of the above stated Privacy Policy as if fully set forth below and your rights under the CCPA are intended to supplement the rights set forth herein.

 

Right to Know / Access

 

California residents have the right, (upon a verifiable request) to request the following:

1. The categories of personal information we have collected about you.
2. The categories of sources from which personal information is collected.
3. The business or commercial purpose for collecting or selling personal information.
4. The categories of third parties with whom we share personal information.
5. The specific pieces of personal information we have collected about you.

 

Please note that EcomGraduates may need to identify you and to ask for additional information in order to be able to fulfill your request. You can make your request by contacting support@ecomgraduates.com. In both instances, you may be required to provide your email address on file with us among other information. We will acknowledge your request within 10 days. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.

 

To make this request, please include in the title “Personal Data Request”. For this request, also include your order number or email address. We may request additional information to verify your identity.

 

Right to Request Deletion of Personal Information

 

California residents have the right to request deletion of their personal information collected or maintained by EcomGraduates.

 

Right to Non-Discrimination for the Exercise of Your California Privacy Rights Discrimination

 

You have the right not be discriminated against because you exercised any of your rights under California law.

 

Authorized Representative

 

You have the right to designate an authorized agent to make any CCPA request on your behalf. EcomGraduates reserves the right to ask for proof that such agent is in fact authorized by you.

 

Information for Individuals not Located in the European Union.

 

If you reside within the European Economic Area (“EEA”), our processing of your personal information will be legitimized as follows:

 

• Whenever we require your consent for the processing of your personal information such processing will be justified pursuant to Article 6(1) lit. (a) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This article in the GDPR describes when processing can be done lawfully.

 

• If the processing of your personal data is necessary for the performance of a contract between you and EcomGraduates or for taking any pre-contractual steps upon your request, such processing will be based on GDPR Article 6(1) lit. (b).”). If this data is not processed, EcomGraduates will not be able to execute the contract with you.

 

• And where the processing is necessary for the purposes of EcomGraduates’ legitimate interests, such processing will be made in accordance with GDPR Article 6(1) lit. (f), for example to detect fraud.

 

If you are a resident of the EEA, you have certain data protection rights. EcomGraduates aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed about what Personal Information, we hold about you and if you want it to be removed from our systems, please contact us at support@ecomgraduates.com.

 

In certain circumstances, you have the following data protection rights:

 

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where EcomGraduates relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

 

Information for Individuals not Located in the European Union.

 

If you are not from the EEA but wish to learn about what Personal Information we may have collected about you or wish to amend, change, delete, or remove your Personal Information, please contact support@ecomgraduates.com and EcomGraduates will attempt to resolve your request if reasonably possible. 

 

 

We can only discuss matters relating to your purchases and use of the Website through the email address used when the purchases are made. We cannot change, update, delete, or handle any other matters relating to any purchases made on the Website except with the individual who passed such order and through such original email address. We cannot provide any information regarding a purchase order over the phone or by any other method except through the email address on file.

 

ARE CHILDREN UNDER THE AGE OF 18 ALLOWED TO USE THE WEBSITE AND “DO NOT TRACK” SIGNALS?

 

We do not knowingly collect information from children under the age of 16.  If we learn or have reason to suspect that a user is under age 16, we will promptly delete any such Personal Information.

 

We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Website. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Website. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the Website. If you are under the age of 18 and have already provided personal information through the Websites, please have your parent or guardian contact us immediately using the information. if you have concerns regarding the potential collection of your child’s information. Please contact us at support@ecomgraduates.com so that we can remove such information from our files.

 

CALIFORNIA MINORS ONLY: Businesses are not permitted to sell your information unless you are between 13 and 16 years of age, or your parent, if you are under 13 years of age have affirmatively authorized the sale/sharing of your information. This is the right to opt-in. If you are under 13, we do not seek to engage with you in any transaction, tracking by cookies or otherwise.

 

We do not support Do Not Track ("DNT"). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

 

HOW CAN I OPT-OUT OF PROMOTIONAL EMAILS?

 

If at any time, you no longer want to receive promotional e-mails and/or direct mailings, you may unsubscribe from our emails by following the instructions in the bottom of the email.

 

WHERE IS THE WEBSITE OPERATED AND WHERE IS MY INFORMATION STORED?

 

The Website is operated in the United States. EcomGraduates may share your information with its business partners and service providers outside the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States, and may be transferred to such other countries where EcomGraduates has service providers. Additionally, if you are located in the United States, your information may also be shared with EcomGraduates business partners located outside the United States. By providing us with any information through the Website, you consent to this transfer. If you are outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use this Website and you should opt-out of the collection of cookies and other information-gathering tools. If you are located in the United States and do not wish to allow the transfer of your personal information to third party service providers outside the United States, you should not use this Website and you should opt-out of the collection of cookies and other information-gathering tools.

 

WHEN IS THIS PRIVACY POLICY EFFECTIVE AND WHEN CAN IT BE CHANGED?

 

This Privacy Policy is effective as of the date stated at the beginning of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Website as soon as they go into effect; however, we may do so without notice to you. By accessing the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

 

HOW TO CONTACT US?

 

If you have questions about this Privacy Policy, please e-mail us at support@ecomgraduates.com “PRIVACY POLICY” in the subject line, or visit our contact page on the Website.