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Privacy Policy

Revised on: November 11, 2024

  1. Introduction

Ansira Partners II, LLC (“Ansira”) is committed to protecting your online privacy while providing you with the most useful and enjoyable web experience possible. This Privacy Policy describes how your personal information is collected, used, and shared by Ansira when you visit websites or services controlled by Ansira or where this Privacy Policy is posted (“Site”), and personal information we collect through the services we provide to advertisers, publishers, agencies, and other businesses across third-party websites and online media (the “Solutions”). We may update this Privacy Policy from time to time, as detailed below. If you have a question about how your personal information is being used, you can contact us through the methods provided in the “How to Contact Us” section at the end of this Policy.

This Policy does not override any specific contracts agreed to by the parties and relationships that may be governed by further privacy agreements. If you are engaging with us on behalf of others in your company or otherwise providing the personal information of others, by engaging with us, you acknowledge and agree that you have the consent of those individuals. We recognize that personal and company information that is entered in this site may be confidential or sensitive in nature. Ansira services are designed to be resistant to the inappropriate access or disclosure of such information to other registered and unregistered users.

By using our Site or Solutions, you consent to the collection, use, and disclosure of your personal information by Ansira in accordance with the terms of our Privacy Policy in place at that time. WHEN YOU ACCESS OUR WEBSITE, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, IMMEDIATELY STOP ACCESSING OUR WEBSITE.

  1. Notice at Collection

Ansira may collect or process various categories of personal information, such as when you send a user submission to Ansira, or use Ansira’s web site. The sections titled “Categories of Personal Information or Sensitive Personal Information That We May Collect” contains information on the categories of personal information collected. As an overview, we collect: identifiers; financial information solely for the purpose of e-commerce transactions (if applicable) that are verified by a PCI compliant processor; commercial information; internet or other electronic network activity information; audio, electronic, visual, or similar information; and sensitive personal information such as precise geolocation information. We collect this information to provide, maintain, and improve our Services, including your in-store and online ordering experience, and for other reasons listed in the section, “Purposes of Processing of Personal Information.” We will retain your information for as long as needed to fulfill the purpose for which it was collected and to comply with our legal obligations, resolve disputes, and enforce our agreements. We only collect sensitive personal information, such as precise geolocation information, to provide our Site or Solutions and we delete this information as soon as our Solutions are complete. We may disclose your personal information as outlined in the section, “Disclosure of Personal Information.” We may sell or share identifiers, commercial information, internet or other electronic network activity information, and inferences drawn from any of the information listed above. To exercise your right to opt-out of the sale or sharing of your personal information for targeted advertising, or to limit our use of your sensitive personal information, please visit the “California Residents” section in Section 10 (A) of this Policy.

  1. Categories of Personal Information and Sensitive Personal Information We May Collect

We classify “Personal Information” as information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Ansira may have collected the following information from you within the past 12 months:

Information Collected Directly From You

When purchasing a Ansira Solution or registering for our Site, we collect the appropriate personal information to fulfill your request. This information may include:

  • Identifiers, such as full name, email address, postal address, and phone number;
  • Employment information, such as company name, associated company name, business phone number and your title at the company;
  • Financial information, such as credit card number, account information, and billing address;
  • Protected classifications, such as date of birth or gender; and
  • Content of communications when you contact Ansira about our Solutions.

Information Collected Automatically

We, and partners working on our behalf, may use log files, cookies, or other digital tracking technologies to collect the following information from the device you use to interact with our Site or Solutions. This personal information may include:

  • Device information, or other internet or electronic network activity information, such as Internet Protocol (IP) address, browser type and version, operating system and platform, time zone setting and Internet service provider;
  • Commercial information, such as transaction information, billing and payment records, or your order history;
  • Geolocation information, which may include either coarse geolocation information (such as IP address), or precise geolocation information (such as GPS data when using certain mobile applications) which may be considered sensitive personal information under some applicable state privacy laws;
  • Audio, electronic, visual, or similar information, such as audio recordings when you contact us, or photographs, and video recordings when you attend our events;
  • Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps, and they may use that information to better target advertisements to you on our behalf.

Please see the section “Tracking Technologies We Use” for more information about our use of digital tracking technologies and how to control your personal information.

Information We Collect from Other Sources

We may collect the following information about you from third-party sources:

  • Identifiers, demographic information, and information about your interests and purchases from consumer data providers;
  • Information about your credit history from credit reporting agencies;
  • Information about your interests, activities, and employment history from social networks and other places where you choose to share information publicly; and
  • Information about your interaction with advertisements on our Services, or ads that we place on third party websites, from online advertising companies.

Information Collected from Job Applicants

When you apply for a job with Ansira, we may collect information from you, including:

  • Employment information, such as your current employer, job title, or job description;
  • Education information, such as your education transcripts and level of education;
  • Health information, if you share your health or disability status;
  • Publicly available information that you make available in your social media accounts or that is otherwise available publicly;
  • Sensitive personal information, such as a state identification card or driver’s license, and racial or ethnic origin;
  • Other information, such as information that you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Information Collected from Children

The Sites and Solutions are intended for users aged eighteen and older. We do not knowingly collect information from children and if we discover that we have inadvertently collected information from individuals under the age of eighteen, we will delete that information. Please contact us with any concerns.

Please note: We may make inferences drawn from any of the above categories to determine characteristics, preferences, attitudes, abilities, or behavior.

  1. Purposes of Processing Personal Information

‍We may use the information we collect to operate our business and as otherwise permitted by law, such as:

  • To respond to your inquiries;
  • To provide our Sites and Solutions, including to create, schedule, deliver, customize, and/or optimize advertisements;
  • To provide information and reports to advertisers, agencies, and publishers who use our Solutions,
  • To operate, personalize, and improve our Sites and Solutions;
  • For internal business purposes, such as to analyze trends, administer the site, and track user movement for aggregate use.
  • For security and troubleshooting purposes, including fraud detection, and to provide customer support;
  • To send updates that may be of interest to you;
  • To comply with the law and to maintain the security of our Sites and Solutions; or
  • With your consent, or as otherwise disclosed at the time information is collected.

 

  1. Disclosure of Personal Information

 

We may share the personal information we collect with other parties, including the following:

  • With our partners, including advertisers, agencies, and publishers who use our Solutions, as well as third-party services providers these partners may use;
  • With third-party service providers who process information on our behalf, such as cloud-based data hosting services, and email service providers, to the extent necessary to perform services for us;
  • With advertising technology companies we work with to provide our Solutions, such as demand side platforms and companies delivering advertisements;
  • With any affiliates or joint venture partners that we may have in the future;
  • As part of a corporate sale, merger, or acquisition, or other disposition of all or part of our assets;
  • Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law;
  • With your consent or direction, or as otherwise disclosed at the time information is collected; or
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations, or suspected violations of the Ansira Terms of Use, or as otherwise required by law.

Aggregated or De-identified Data: We may provide third parties with aggregate statistics about our customers, traffic patterns, and related information we collect. This data reflects site usage patterns gathered during users’ visits to our website each month, but it does not contain behavioral or identifying information about any individual member. We may share information we have collected through the Site that has been de-identified or aggregated without limitation. In addition, we may share information that we have collected through the Services that has been de-identified or aggregated more broadly when permitted by our partners.

Sale or Sharing of Personal Information: We may sell or share identifiers, commercial information, internet or other electronic network activity information, and inferences drawn from any of the information listed above. Please see the section “Privacy Rights for Specific Jurisdictions” below for more information as to how to exercise your rights.

  1. Tracking Technologies We Use

As discussed in Section 3, Ansira and our service providers use cookies, beacons, and embedded scripts in connection with our sites.

“Cookies” are small pieces of information that some websites store on your computer’s hard drive when you visit them. Cookies typically contain information about the user (i.e., username, site display preferences, etc.) with respect to a specific website. Like many other websites, we may set and access session cookies on your computer to customize the user experience and to identify members so they don’t have to enter a user id and password upon each visit.

Most web browsers automatically accept cookies but allow you to modify security settings so you can approve or reject cookies on a case-by-case basis. You may realize certain losses of functionality if you turn your cookies off in your browser. However, if you do not use cookies, you can still access all of the features on our site by logging in manually with each visit. Declining and/or deleting cookies on one browser may not delete them on all browsers. If you use multiple browsers on your device, you may need to change setting and delete cookies in each browser. Choices and decisions related to Ansira website cookies on one device will not transfer across devices. Actions to opt-out should be done on each device used to access our website.

To opt-out of the vendors we use for cross-device linking, go to the Digital Advertising Alliance’s Choices page at www.aboutads.info/choices and perform a global opt-out on each browser and device that you would like to be opted out on. To opt-out of our interest-based advertising online and in third-party mobile applications, visit Digital Advertising Alliance’s Choices page here and perform a global opt-out.

Beacons are small graphical images (also known as “pixel tags” or “clear GIFs”) that may be included on our sites and typically work in conjunction with cookies to identify our users and user behavior.

Embedded Script is a programming code that is designed to collect information about your interactions with the site, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the site, and is deactivated or deleted thereafter.

Third-Party Analytics. We utilize third party service providers that may use cookies or other technologies to collect information about your online activities across Ansira sites. These providers are used for non-advertising purposes. To understand the choices they may provide you to control these activities please visit the following websites:

 

Do Not Track and Opt-Out Preference Signals: The “Do Not Track” (DNT) privacy preference is an option that may be made available in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them. We currently do not recognize opt-out preference signals, such as the Global Privacy Control (available here), as a request to opt-out of the sale or sharing of your personal information.

  1. Security and Data Retention

We determine the retention period for each of the categories of personal information listed above based on: (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained; (2) any legal or regulatory requirements applicable to such information; (3) internal operational needs; and (4) any need for the information based on any actual or anticipated investigation or litigation.

We have adopted physical, technical, and administrative safeguards to help protect against theft, loss, misuse, and unauthorized access to or disclosure of the information we collect and receive. However, please note that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your personal information.

Personal data you enter on our site is encrypted with secure server software (SSL) that encodes the information before your web browser software sends it to us. The SSL software decodes the data only after it reaches our server, meaning that no one can access any of your personal information while it is in transit. If you register with our Site or Solutions, you are responsible for maintaining the security of your password at all times. You may gain access to and review your personal information by accessing your account. You are responsible for activity occurring while logged into your account.

In the unlikely event that your personal information (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we will notify you by email (at our sole and absolute discretion) using the last email address you have provided to us in the most advantageous time practical under the circumstances. However, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore sensible integrity to the system. Additionally, we would need to evaluate the legitimate needs of law enforcement if notification would impede a criminal investigation and we would need to ensure that we are in compliance with Ansira’s Security Incident Policy and Breach Policy.

  1. Chat Features and Session Replay Technology

 

We may use session replay technology offered by third parties to monitor how you interact with our Site. The personal information collected by this technology may include, without limitation, which links you click on, pages and content you view, information that you type into our online forms and chat features, recordings of mouse clicks and movements, and information about your device or browser. Our Site may also have third-party chat features for support purposes. These features may collect the content of your communications and other personal information you provide while interacting with the chat feature. Please discontinue use of the Site if you do not consent to the collection of such information by us and third parties.

 

  1. International Data Transfers

If you are visiting our Site from a location outside of the U.S., your connection may be through and to servers located in the U.S. Any information you provide during your visit will be processed and maintained on our server and other internal systems located within the U.S. or otherwise as described above. You acknowledge you understand that by providing your personal information to us, your personal information: (i) will be used for the uses identified above in accordance with this Privacy Policy; and (ii) may be transferred to the U.S. as indicated above, in accordance with applicable law.

We take the privacy of our users seriously and therefore take steps to safeguard your information, including ensuring an adequate level of data protection in accordance with E.U. standards in effect as of the date of this Privacy Policy. These steps include use of the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA, U.K., and Switzerland in accordance with European Union data protection laws. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

By using the Site or Solutions and/or providing us with personal information, you acknowledge this transfer, which may not offer the same level of data protection as the country where you reside, in accordance with the terms of this Privacy Policy and you do not require separate notification of each such transfer that occurs.

  • Privacy Rights for Specific Jurisdictions
  1. CALIFORNIA RESIDENTS

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights around Ansira’s collection, use, and sharing of their personal information. Ansira provides a description of the personal information it collects from you, the purposes for which that information is used, and how that information may be disclosed in Section 3 (Categories of Person Information and Sensitive Personal Information We May Collect), Section 4 (Purposes of Processing Personal Information) and Section 5 (Disclosure of Personal Information), respectively.

 

If you are a resident of California, you may have the following rights:

  • You have the right to know and right to access informationabout the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information. You also have the right to know if we have sold or disclosed your personal information. You may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form.
  • You have the right to request the deletion of your personal information, subject to certain legal exceptions.
  • You have the right to opt out of the sale or sharing of your personal informationto third parties.
  • You have the right to correct your personal information if inaccurate.
  • You have the right to limit the use and disclosure of your sensitive personal information if we use such information to infer characteristics about you. Note that for precise geolocation information collected through a mobile device, you will need to update your settings. To do this on an iPhone, (1) go to Settings > Privacy > Location Services > and choose an app; (2) Select the app > tap on “location;” (3) Scroll down and slide the “Precise Location” toggle to Off. To do this on an Android, (1) go to Location Services > Google Location Accuracy; and (2) Toggle Improve Location Accuracy to Off.
  • You have the right to not be discriminated againstfor exercising any of these rights, including where financial incentives are offered.
  • You have the right to opt out of profiling using automated decision-making technology.You may have the right not to be subject to a decision based solely on profiling, except under certain exceptions under local law.

Financial Incentive Programs: Ansira does not offer financial incentives associated with our collection, use, or disclosure of your personal information.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us using the information below.

Submitting California Rights Requests: You may send your request by email to [email protected] or by phone to 866-464-4342. An authorized agent, such as another individual or business, may submit a request on your behalf. We will not discriminate against you for exercising your rights under the CCPA.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

We must verify your identity before responding to your request. We may verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity. We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

  1. RESIDENTS OF OTHER U.S. STATES

Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia may have the following rights:

 

  • The right to opt out of “sales” of personal information and use of your personal information for “targeted advertising,” as those terms are defined under applicable law.
  • The right to opt out of “profiling” under certain circumstances, as defined under applicable law. (Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, and Virginia only.)
  • The right to access and the right to confirm processing of your personal information under certain circumstances.
  • The right to obtain a copy of, or representative summary of, your personal information in a portable and, to the extent technically feasible, readily usable format.
  • The right to obtain a list of the categories of third parties to which we have disclosed your personal information. (Residents of Delaware and Maryland only.) Residents of Minnesota and Oregon have the right to request a list of the specific third parties to which we have disclosed your personal information. Rhode Island residents have a right to request the identity of all third parties to whom we have sold personally identifiable information.
  • The right to question the result of profiling, where your personal information is profiled in furtherance of decisions that produce legal or similarly significant effects concerning you. This includes the right to be informed of the reason the profiling resulted in the decision, be informed of what actions you might have taken and can take to secure a different decision in the future. You also have the right to review the personal information used in the profiling and have the data corrected and the profiling decision reevaluated based upon any corrected personal information. (Residents of Minnesota only.)
  • The right to correct personal information under certain circumstances. (Residents of Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, and Virginia only.)
  • The right to delete personal information under certain circumstances.

 

Submitting a Rights Requests: You may send your request by email to [email protected] or by phone to 866-464-4342. For residents of Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, and Texas an authorized agent, such as another individual or business, may submit a request on your behalf. We will not discriminate against you for exercising your rights under applicable law.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

We must verify your identity before responding to your request. We may verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity. We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

Residents of Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Texas, and Virginia have the right to appeal a denial of their request by contacting us as described in the notice of denial.

  1. NEVADA RESIDENTS

Residents of Nevada have the right to opt-out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us by sending your request via email to [email protected] or by phone to 866-464-4342.

  1. RESIDENTS OF THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM, AND SWITZERLAND

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”). If you are located in the EEA, U.K., or Switzerland, you have the following rights:

 

  • The right to access information about the categories of personal data we have collected about you. You may also request a copy of the personal data we have collected, and upon request, we will provide this information to you in a machine-readable electronic format or transfer it to a third party.
  • The right to correct your personal data if inaccurate.
  • The right to request erasure of your personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
  • The right to withdraw your previously given consent for us to process your personal data.
  • The right to restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise, or defense of legal claims; or if your request to object to processing is pending evaluation.
  • The right to object to processing of your personal data based on our legitimate interests, for direct marketing, and to object to decisions being made based solely on automated decision making and/or profiling. When you object, we will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
  • The right to obtain information about, and a copy of, the safeguards we use to transfer personal data across borders.

 

In processing personal data, we may rely upon the following lawful bases:

 

  • Consent. We may process personal information with the consent of the individual whose data is being processed and/or in reliance upon the consent of the administrator of the account, who must affirm that s/he has obtained appropriate consent from all participants.
  • Contract. When we enter a contract with you and/or an administrator for your account, we process personal information on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract. This is necessary for us to provide the Websites to you.
  • Vital interests. In a case where the personal information is required to protect your vital interests or the vital interests of another natural person, then this may be used as the lawful basis of the processing. For example, we may need to process personal information in the event of a pandemic.
  • As required by law. We may process personal information as required to comply with legal obligations to which we are subject for the for the purpose of compliance with EEA, UK, or Swiss public, governmental, judicial, or other regulatory authorities.
  • For legitimate business purposes. This includes but is not limited to legal compliance and the purposes described above.

Users who are located in the European Economic Area (“EEA”), the U.K., or Switzerland may also have the right to lodge a complaint about our data collection and processing actions with the relevant supervisory authority in their country of residence. Contact details for data protection authorities are available here:

If you are a resident of these countries and would like more information about our data sharing practices, please contact us using the information below.

Ansira Partners II, LLC

ATTN: Legal Department

2300 Locust St.

St. Louis, MO 63103

[email protected]

 

  1. Changes to this Privacy Policy

Ansira may update or revise this policy at any time, at its sole discretion. Users should review this Privacy Policy from time to time to make sure that they stay informed of its terms and conditions.

  1. How to Contact Us

Ansira Partners II, LLC

ATTN: Legal Department

2300 Locust St.

St. Louis, MO 63103

[email protected]