Privacy Policy

YOUR PRIVACY IS IMPORTANT TO FIVE CROWNS MARKETING

This Privacy Policy and Notice to Consumer (“Privacy Policy”) describes Five Crowns Marketing’ practices with respect to the collection, use, and disclosure of personal information it has collected within the past 12 months. Five Crowns Marketing does not sell any of the personal information it collects. This Privacy Policy also provides information about consumers’ rights, under California law, with respect to the personal information Five Crowns Marketing collects about them.

This Privacy Policy describes the Five Crowns Marketing’ generalized practices only and does not provide any specific information regarding Five Crowns Marketing’ activities with respect to any individual consumer’s personal information.

ACCESSING THE PRIVACY POLICY

If you are unable to access this policy because of a language barrier, disability, or any other reason, please contact Five Crowns Marketing via phone at (760) 344-1930 or via email at ks@fivecrowns.com so that Five Crowns Marketing can provide you with a version of the Privacy Policy that is accessible to you.

DEFINITIONS

The terms used in this Privacy Policy shall have the same definitions given to them by the California Consumer Privacy Act (“CCPA,” Cal. Civ. Code §1798.100 et seq.), the regulations to the CCPA, and the California Online Privacy Protection Act (“COPAA,” Cal. Bus. & Prof. Code §22575 et seq.).

ACCEPTING THE TERMS OF THE PRIVACY POLICY

You consent to and agree to the terms of this Privacy Policy by expressly accepting the terms of this Privacy Policy or by using our website.

Five Crowns Marketing reserves the right to change this Privacy Policy at any time without notice. Any changes we make to the Privacy Policy will be reflected in the Privacy Policy posted to our website. To the extent Five Crowns Marketing decides to disclose or use your personal information in a manner different from the manner specified at the time the information was collected, advanced notice will be provided. Otherwise, Five Crowns Marketing’ use and disclosure of personal information collected will be done in accordance with the version of this Privacy Policy in effect at the time the information was collected.

FIVE CROWNS MARKETING’S COLLECTION AND USE OF PERSONAL INFORMATION

Five Crowns Marketing respects each person’s right to privacy, including the right to data privacy. Therefore, Five Crowns Marketing processes sensitive personal data only as needed to meet legal obligations and retains all personal information securely in compliance with all applicable laws.

Information Five Crowns Marketing May Affirmatively Collect and How We Use It

You are generally free to view Five Crowns Marketing’ website without providing any personal information about yourself other than the data and usage information that is passively collected by our website, as discussed below.

However, Five Crowns Marketing may collect additional information directly from you when you provide it to us through our website. For example, Five Crowns Marketing may collect information from you when:

  • You request customer support.
  • You otherwise provide it to use when communicating with or contacting us directly.

The general categories of information Five Crowns Marketing may collect directly from you includes:

  • Identifiers – Including signatures, addresses, telephone numbers, and email addresses.

Five Crowns Marketing uses this information to customize and personalize your experience with our Company and its products. We may use the information we collect from and about you for a variety of business purposes, including responding to your customer service requests, improving customer experience and engagement, and enhancing our content, products, and services. Specific ways in which Five Crowns Marketing may use the information we collect from and about you includes:

  • Responding to your inquiries and contacting you when necessary.
  • Addressing problems with our website or our business and protecting the security or integrity of our website and our business.
  • For other business purposes specifically disclosed at the time you provide your information to Five Crowns Marketing.

Information Five Crowns Marketing, or Our Service Providers, May Automatically Collect from You and How it is Used

Whenever you visit or interact with our website, Five Crowns Marketing and our service providers may use cookies, web beacons, pixel tags, log files, or other technologies to automatically or passively collect information about your online activity.

A cookie is a small piece of data stored on your computer or mobile device by your web browser. Web browsers typically offer you the ability to disable the use of Cookies. We use Cookies to identify the areas of our website that you have visited and to aggregate information regarding website traffic and interaction. Using Cookies, and other similar tools, allow us to personalize your website experience and the content that you see on our website.

We also utilize Google Analytics to collect information about the use of our website. Google Analytics, one of our service providers, may collect information such as how often you visit our website, what pages you visit on our website, when you visit the pages, and other websites you may have visited prior to accessing our website. Using Google Analytics allows Five Crowns Marketing to improve our website and your experience with our website. The terms governing Google Analytics collection and use of personal information in its role as Five Crowns Marketing’ service provider may be found here:

https://marketingplatform.google.com/about/analytics/terms/us/

and here:

https://privacy.google.com/businesses/processorterms/ccpa/.

The general categories of information Five Crowns Marketing and/or its service providers may automatically collect from or about you includes:

  • Internet or Other Electronic Network Activity – Including, but not limited to, computer device information including internet protocol (“IP”) addresses or other unique identifiers from a computer, mobile device, tablet, or other device used to access our website such as browser type, device type, and the domain name from which you access our site; usage information, including information about how you use our website such as the date and time you visit our website, the amount of time you spent on our website, the number of times you return to the website, information regarding which portions of our website you access, information regarding whether you open, forward, or click on the links we include in our emails to you, and other websites you may visit; location information, including information about where traffic on our website is coming from based on the location of a user’s IP address; and cookies, which are pieces of data stored on a web user’s hard drive that contain information about the user’s browsing activities.

Five Crowns Marketing uses this information to customize and personalize your experience with our Company and its products. We may use the information we collect from and about you for a variety of business purposes, including to respond to your customer service requests, to improve customer experience and engagement, and to enhance or improve our content, products, and services. Specific ways in which Five Crowns Marketing may use the information we collect from and about you includes:

  • Responding to your inquiries and contacting you when necessary.
  • Addressing problems with our website or our business and protecting the security or integrity of our website and our business.
  • For other business purposes specifically disclosed at the time you provide your information to Five Crowns Marketing.

Information Regarding How Five Crowns Marketing, and Our Service Providers, May Share the Personal Information We Collect from You 

Five Crowns Marketing does not sell, trade or rent personal information about its users for monetary or other consideration. Any and all information we collect from you will be used only to support our relationship with you. We will never send unsolicited communications via email, and you can unsubscribe from our services at any time.

We instruct our service providers to refrain from selling the information they collect on our behalf and to refrain from using the information they collect on our behalf for purposes other than the specific services that we hire them to provide.

Five Crowns Marketing does not share the information comprising the categories of personal identifiers, protected classifications, or commercial information with any third parties or service providers in the ordinary course of business. Five Crowns Marketing may share the information comprising the category of internet or other electronic network activity information with its service providers or other third parties who assist Five Crowns Marketing in operating its website, or the information may be collected in the first instance by our service providers on our behalf.

Despite these general business practices, Five Crowns Marketing may share the personal information we, or our service providers, collect if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith belief may violate federal, state, or local laws; or (4) exercise or defend legal claims. Sharing information we, or our service providers, collect may also be necessary when such information is an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which a third party may assume control of all or part of our business.

HOW FIVE CROWNS MARKETING PROTECTS THE INFORMATION WE COLLECT

Five Crowns Marketing has implemented and maintains reasonable security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, exfiltration, theft, and disclosure. Five Crowns Marketing takes commercially reasonable precautions to prevent unauthorized access or disclosure to your personally identifiable information, to maintain data and information accuracy, and to facilitate the appropriate use of information. All information you provide to us is stored on our or our service providers’ secure servers behind firewalls. We have implemented a variety of encryption and security technologies and procedures to protect information stored in our computer systems from unauthorized access. We use physical, electronic, and managerial procedures to protect the personally identifiable information we collect online. We also maintain procedural safeguards that restrict access to personally identifiable information to employees (or people working on our behalf and under confidentiality agreements) who need to know such information in order to provide the products and services that you request. Additional database content is protected either by means of a two-key encryption algorithm Secure Socket Level (“SSL”) encryption, and/or behind a Web Application Firewall (WAF) designed to protect, identify and prevent attacks against the website.

The safety and security of your information also depends on you. Please be sure to maintain the confidentiality of your personal information and refrain from sharing it with others.

CHILDREN’S PRIVACY

Five Crowns Marketing’ website is not directed at children under 13 years of age, nor does Five Crowns Marketing knowingly collect information from children under 13. If you are under 13, please do not submit any personally identifiable information to Five Crowns Marketing. Five Crowns Marketing does not sell any personal information, including that of any children under the age of 16.

DEIDENTIFIED AGGREGATED DATA

On some occasions, Five Crowns Marketing may use your data in an aggregated, non-specific format for analytical and demographic purposes. This processing, for example, may include using aggregated, non-specific data based on demographic or location-based information for marketing and customization purposes.

NOTICE TO CALIFORNIA RESIDENTS REGARDING RIGHTS UNDER CALIFORNIA LAW

Effective January 1, 2020, the California Consumer Privacy Act (“CCPA”) grants consumers (California residents) certain rights with respect to their personal information. Five Crowns Marketing respects the privacy rights of consumers and endeavors to make consumers aware of and comply fully with the rights afforded to consumers by the CCPA.

The Right to Know

This Privacy Policy sets forth Five Crowns Marketing’ current and past (within past 12 months) practices related to the general categories of personal information we collect, how we collect it, how we use the personal information we collect, and how, if at all, and with whom we share the personal information. In addition to what is described in this Privacy Policy, consumers have the right to request that Five Crowns Marketing disclose to the consumer the following information:

  • The categories of personal information Five Crowns Marketing has collected about the consumer.
  • The categories of sources from which Five Crowns Marketing collects the personal information.
  • The business or commercial purpose for collecting or selling (to the extent applicable) the personal information.
  • The categories of third parties with whom Five Crowns Marketing shares personal information.
  • The specific pieces of personal information Five Crowns Marketing collects about the consumer.

Five Crowns Marketing will provide this information to a consumer upon receipt and verification of a Verifiable Consumer Request to Know (hereinafter a “Request to Know”). For details on how to submit a Request to Know, see below. Any information provided by Five Crowns Marketing in response to a Request to Know will cover the 12 months preceding the date of the request.

The Right to Request that Five Crowns Marketing and its Service Providers Delete Your Personal Information

A consumer has the right to request that Five Crowns Marketing delete any personal information about the consumer which Five Crowns Marketing has collected from the consumer and direct any service providers acting on its behalf to do the same. Five Crowns Marketing will comply with a consumer’s request to delete his or her personal information upon receipt and verification of a Verifiable Consumer Request to Delete (hereinafter “Request to Delete”).

The CCPA may entitle Five Crowns Marketing to retain certain personal information collected from a consumer, notwithstanding the consumer’s request to delete the same. For example, notwithstanding a consumer’s request to delete, Five Crowns Marketing is entitled to retain the following information:

  • Personal information necessary to complete a contract between the consumer and Five Crowns Marketing.
  • Personal information necessary to detect security incidents.
  • Personal information necessary to identify and repair errors in Company provided products or services.
  • Personal information necessary to exercise any right provided for by law.
  • Personal information necessary to engage in research with information provided for by a consumer with informed consent.

Additional bases that would entitle Five Crowns Marketing to retain a consumer’s personal information, notwithstanding the consumer’s Verifiable Consumer Request to Delete the same, are set forth in California Civil Code §1798.105(d).

The Right to Opt-Out of the Sale of Your Personal Information

Under California law, a consumer has the right to opt-out of the sale of his/her personal information by a business that collects personal information and sells it (“Request to Opt-Out”). However, Five Crowns Marketing does not sell any personal information it collects from consumers. Because Five Crowns Marketing does not sell consumers’ personal information, a consumer does not need to submit any Request to Opt-Out.

The Right to Non-Discrimination for the Exercise of Your Rights Under the CCPA

A consumer has the right to be free from discrimination by Five Crowns Marketing because the consumer exercised any of his/her rights under the CCPA. Examples of discrimination may include:

  • Denying goods or services to you.
  • Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, in a manner that is not justified under the law.
  • Providing a different level or quality of goods or services.

Five Crowns Marketing will not discriminate against consumers who exercise their rights under the CCPA.

Exercising Your Rights Under the CCPA

Consumers may submit a request to exercise their rights under the CCPA by either of the following methods:

A consumer is entitled to utilize an authorized agent to exercise his/her rights under the CCPA. If the consumer chooses to utilize an authorized agent for this purpose and that agent is not acting pursuant to a power of attorney, Five Crowns Marketing reserves the right to require:

  • That the authorized agent submits a writing signed by the consumer in which the consumer authorizes the agent to act in making the request.
  • That the consumer directly verifies his or her identity with the business.
  • That the consumer otherwise directly confirms to Five Crowns Marketing that he/she has provided the authorized agent permission to submit the request.

Any authorized agent submitting a Request to Know on behalf of a consumer should complete and submit a completed California Authorized Agent Designation form to the ks@fivecrowns.com email along with his/her request on behalf of the consumer or provide all the information required by the California Authorized Agent Designation to Five Crowns Marketing when submitting a consumer request via email or toll-free telephone.

Five Crowns Marketing’ Policies and Procedures for Complying with Consumer Requests Pursuant to the CCPA

Five Crowns Marketing follows stringent policies and procedures in responding to any and all consumer requests to exercise their rights under the CCPA.

CONSENT TO PROCESSING OF PERSONAL DATA IN THE UNITED STATES

If you are a resident of the European Economic Area (“EEA”), in order to provide our website and products to you, we may send and store your personal information outside of the EEA, including in the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our website, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

LIMITATION OF LIABILITY

By using our website, you assume the risk of transmitting your information as it relates to the use of this website, and for any data corruptions, intentional interceptions, intrusions, or unauthorized access to this information that are not due to Five Crowns Marketing’ failure to maintain and implement commercially reasonably security measures. Further, you assume the risk of any delays, interruptions to, or failures that prevent the use of this website. In no event shall Five Crowns Marketing or any individual associated therewith be liable for any direct, indirect, special, consequential or monetary damages, including fees, and penalties in connection with your use of material posted on this website. This limitation shall govern your use of our website to the extent permitted by law.

Some portions of our website may contain links to other websites on the internet that are not under our control nor maintained by Five Crowns Marketing. By using this website, you acknowledge that we are providing these links to you only as a convenience and you agree that we are not responsible for the content of these websites, or how these websites use your personal information. Your use of these other linked websites, including social media pages, is subject to the respective terms of use and privacy policies located on those websites.

CONTACT FOR MORE INFORMATION

If you have any questions or concerns about Five Crowns Marketing’ privacy policies and practices, please contact Five Crowns Marketing via phone at (760) 344-1930 or via email at ks@fivecrowns.com.

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