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Privacy Policy

EFFECTIVE DATE: February 7, 2025

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, including in-person events, 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.

 

2. Notice at Collection 

Ansira may collect or process various categories of personal information when you submit information to Ansira or use Ansira’s website. Detailed information about the categories of personal information collected can be found in the section titled “Categories of Personal Information or Sensitive Personal Information That We May Collect.” In summary, we collect the following types of information: identifiers; financial information (solely for e-commerce transactions, verified by a PCI-compliant processor, if applicable); commercial information; internet or other electronic network activity information; audio, electronic, visual, or similar information; and sensitive personal information, such as precise geolocation data.

We collect this information to provide, maintain, and improve our services, including enhancing your in-store and online ordering experience, as well as for other purposes outlined in the section, “Purposes of Processing of Personal Information.” We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. While sensitive personal information such as geolocation data is collected to provide specific site functionalities or solutions, we retain certain geolocation data, such as that captured in Adobe Analytics, as part of our business operations and analytics. The exact retention period for geolocation data depends on its purpose and applicable legal or operational requirements.

We may disclose your personal information as detailed in the section, “Disclosure of Personal Information.” Additionally, we may sell or share identifiers, commercial information, internet or other electronic network activity information, and inferences derived from these categories. 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 “Exercising Your Privacy Rights” section in Section 11 of this Policy.

 

3. 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,  registering for our Site, or providing your personal information directly to Ansira for any other reason, 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.

 

4. 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.

 

5. 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 “Exercising Your Privacy Rights” below for more information as to how to exercise your rights.

 

6. Tracking Technologies We Use 

Use of Cookies, Beacons, and Embedded Scripts

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 websites store on your computer’s hard drive when you visit them. Cookies typically contain information about the user (e.g., username, site display preferences) related to a specific website. Like many other websites, we may set and access session cookies on your computer to customize the user experience and 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 to block or delete cookies. You may experience certain losses of functionality if you disable cookies in your browser. However, even if cookies are disabled, you can still access all features on our site by logging in manually with each visit. Blocking or deleting cookies in one browser does not affect cookies in other browsers or devices. If you use multiple browsers or devices, you will need to adjust settings and delete cookies separately on each.

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 users and understand user behavior.

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

Third-Party Analytics

We use 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, such as site performance analytics. For more information about the data collection practices of these providers, you can review their respective privacy policies.

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.

 

7. 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.

 

8. 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.

 

9. Links to Third Party Websites

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing personal information to third parties, since any personal information disclosed will be handled in accordance with the applicable third party’s privacy policy.

In some cases, we offer links to social media platforms (like Facebook, Instagram, Pinterest, X (formerly known as Twitter) and YouTube) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the Terms of Use and Privacy Policies for those platforms. For more information about how YouTube collects and processes personal information, please see Google’s Privacy Policy.

 

10. 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.

 

11. Exercising Your Privacy Rights
Depending on where you live, you may have the following rights with respect to your personal information under applicable data protection laws:

  • Access – The right to request access to and obtain a copy of any personal information we may have about you.
  • Deletion – The right to delete your personal information that we have collected or obtained, subject to certain exceptions.
  • Correction – The right to request that we correct any inaccuracies in your personal information, subject to certain exceptions.
  • Opt-Out of Certain Processing – The right to: (a) opt out of the processing of your personal information for purposes of targeted advertising, (b) opt out of the sale or sharing of your personal information; and (c) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
  • Objection/Restriction of Processing – The right to object or restrict us from processing your personal information in certain circumstances.
  • Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your personal information.
  • Automated Decision-Making – The right to know when you are subject to automated decision-making, the personal information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
  • Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

To exercise any of the privacy rights afforded to you under applicable data protection laws, e-mail us at [email protected].

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you withdraw your consent or object to processing of your personal information, or if you choose not to provide certain personal information, we may be unable to provide some, or all, of our Services to you.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your personal information. We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

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. This section provides additional information regarding Ansira’s practices pursuant to the CCPA.

Please see the below chart for detailed information about the categories of personal information we have collected from California residents during the twelve months preceding the date on which this Policy was last updated and the categories of third parties to whom we sell or share personal information.

Personal Information Category set forth in Cal. Civ. Code § 1798.140  Categories of Third Parties to Whom We Sell or Share Personal Information 
Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. Third-party marketers and other third parties that set cookies and other online tracking technologies on our Site.
California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc. We do not sell or share this category of Personal Information.
Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion. We do not sell or share this category of Personal Information.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement. Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site
Geolocation data, such as your IP address. Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.  We do not sell or share this category of Personal Information.
Professional or employment-related information. Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.

 

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 above.

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

Our legal basis for processing personal information depends on the personal information involved and the context in which we process it. 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]

 

12. 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.

 

13. How to Contact Us

Ansira Partners II, LLC
ATTN: Legal Department
2300 Locust St.
St. Louis, MO 63103
[email protected]