PRIVACY POLICY

2. Types of Information We Collect

When you interact with us through the Services, we collect the information you provide, usage information, and information about your device. We may also collect information about you from other sources like Service Providers (defined below), and optional programs in which you participate, which we may combine with other information we have about you. Here are the types of information we collect about you:

(A) Personal Information

“Personal Information” is information that identifies, relates to, describes, or can be reasonably linked to, directly or indirectly, a particular individual or household. We may collect Personal Information from you on or through the Services in a variety of ways, including when you register on the Websites, purchase a Service or merchandise, participate in online contests, surveys, or games (if applicable), or sign-up for a newsletter or subscription. We also may, from time to time, receive Personal Information about you from third-party sources to improve the Services, and for the various purposes outlined in this Privacy Policy. We have grouped together the following categories of Personal Information to explain how we use this type of information (to the extent we collect it). These terms are used throughout this Privacy Policy:

• “Personal Identifiers”, including your first and last name, birthdate, age, gender, username, and social security number.
• “Contact Information”, including your email address, phone number, and home address.
• “Biographical Information”, including your level of education and professional background.
• “Financial Information”, including your credit card number and purchasing history.

(B) Device Identifiable Information


We may collect information that may not reasonably identify you or a household personally, but is linked to your computer or device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of providing the Services. When you visit our Websites to browse, read, or download information, we automatically collect information about your computer that your browser sends, such as your internet protocol (“IP”) address, browser type and language, access times, pages visited, and referring website addresses. We may use Device Identifiable Information to analyze trends, help administer the Services, track the online movement of users, learn about and determine how much time visitors spend on each page of the Websites, how visitors navigate throughout the Websites or use other Services, and gather broad demographic information for aggregate use. We may also collect Device Identifiable Information through “cookies” or “web beacons” as explained below.

In addition, we may collect information about your mobile device such as the type and model, operating system (e.g., iOS or Android), carrier name, mobile browser (e.g., Chrome or Safari), applications using our Websites, and identifiers assigned to your device, such as its iOS Identifier for Advertising (“IDFA”), Android Advertising ID (“AAID”), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID.

We may also collect your location information, such as your zip code or the approximate geographic area provided by your Internet service provider (“ISP”) or location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled. When aggregated or deidentified information, including Device Identifiable Information, is directly associated with Personal Information, such that the aggregated or deidentified information can be reasonably associated with a particular individual user or household, then this aggregated or deidentified information is treated as Personal Information.

3. Types of Information We Collect

(A) Cookies and Web Beacons


To help us serve you better, we may collect Device Identifiable Information from you through technologies such as “cookies” and “web beacons” (which are also called clear GIFs, pixel tags, or pixels) or by tracking IP addresses.

• “Cookies” are small data files that are stored by your web browser when you interact with a website. When you visit a webpage, the cookie sends back Device Identifiable Information.
• “Web beacons” are small graphic images (usually invisible) that can be embedded in content and ads on a webpage that track usage of the Websites and effectiveness of communication. These web beacons can then be used to recognize our cookies and to monitor certain user interactions with a website.

Cookies operate in the background and you can turn them off by adjusting your Web browser settings, but doing so may make it difficult to use some of the features on the Websites or the features may not be available to you. We may use cookies to make your Website experience easier by, for example, remembering your preferences, keeping track of your login name, password and, if such Services are available on the Websites, if you want to buy things while on the Websites, your “shopping cart.”

We may also use cookies and other activity tracking tools on the Websites and through other Services to collect your engagement metrics, including your Personal Identifiers and Device Identifiable Information, related to your activity on the Websites and Services.

For more information on your choices regarding cookies, you can review the FTC’s guide to opting out of online tracking for computers and mobile devices. You can also see Section 7 for ways to opt-out. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The Websites and Services do not currently support Do Not Track requests.

(B) Other Direct Interactions with You


You give us your information in your direct interactions with us. We collect information you provide to us when you register accounts on our Websites and other Services; request tickets (if applicable), newsletters, and other products, services, or information from us; respond to surveys; participate in sweepstakes or contests (if applicable); or otherwise interact with us. This information includes Personal Identifiers, Contact Information, Biographical Information, Financial Information, and Device Identifiable Information, which you give us from time to time.

Except for IP addresses, we may match Device Identifiable Information with Personal Information that we may have from or about you, which would allow us to identify you. We may use this information to provide you with offers that are available where you physically are located.

(C) Social Media

When using the Services or when using certain third party social networking services (e.g., Facebook, Twitter, etc.) (each, a “Social Network”), you may have the option to connect your Service information and activity with your Social Network information and activity. If you authorize such a connection, you permit us to share or publish information about your Service activity with that Social Network and its users, and to access certain of your Social Network information, as disclosed to you at the time you consent to the connection. Information we may share with a Social Network may include technical information about your Service activity, your Service comments, or the videos you watch on the Service. Information we may access about you, with your consent, from a Social Network may include, but is not limited to, your basic Social Network information, your location data, your list of contacts, friends or followers and certain information about your activities on that Social Network. If you permit a connection between a Social Network and a Service, we (and that Social Network) may be able to identify you and to associate information received pursuant to the connection with information we already have about you. For more information, please review the privacy disclosures and terms of your Social Network account(s), which govern how that account information is collected and shared with us.

(D) Other Third Party Sources

WFC LA may also receive other information from Service Providers in connection with the operation of our Services, including, if applicable, when you purchase our tickets or take our surveys through a third-party vendor. We may also receive information from Service Providers through marketing and demographic studies that we use to supplement Personal Information and deidentified information provided directly by you.

4. How We Use Your Information

For the Purpose Collected: If you provide Personal Information for a certain reason, we will use the Personal Information in connection with the reason for which it was provided. For instance, if applicable, if you make an online purchase, we will use your credit card information to fulfill and process your purchases. Also, if you register or open an account on the Services, the Personal Information you provide may be used to maintain your account, provide you access to certain features of our Services, or offer you the benefits and privileges that typically come along with registration. These benefits may include access to and use of exclusive or personalized content or activities, participation in special events and promotions (such as contests and sweepstakes), and delivery of products or merchandise. As part of these activities, we may use your Personal Information to determine your eligibility, notify you whether you are a winner and/or fulfill and deliver prizes and orders.

Support from Service Providers: In addition, Personal Information and Device Identifiable Information that we collect may be used by us and by third-party service providers, such as hosting providers, data management companies, address list hosting companies, email service providers, analytics companies (e.g., Google Analytics), distribution companies, fulfillment companies, and payment processors (collectively, “Service Providers”) for a variety of purposes, including to:

• Contact you about the Websites and/or Services you have requested;
• Provide you with Services or information you have requested, or products or services you have ordered or signed up for, such as newsletters;
• Confirm or fulfill an order you have made (if applicable);
• Administer your participation in a contest, sweepstakes, promotion, survey, or voting poll;
• Facilitate the operation, maintenance and improvement of the Services, our business operations, and internal record keeping;
• Provide you with advertising that may be more relevant to you; and
• With your permission, send you promotional material or special offers from WFC LA, our marketing partners or other third parties. If you no longer wish to receive promotional emails from us, or have your information shared with third parties as previously described, you may change your mind and/or your preferences by following the directions in Section 7.

Our Service Providers are given the information they need to perform their designated functions in connection with the Services, and we do not authorize them to use or disclose your Personal Information for their own marketing or other purposes.

Identity Verification and Security: We also may obtain information about you from other businesses to verify your identity so we can properly process your requests and prevent fraud. By accessing and using our Services, you agree that we may use your submitted and obtained Personal Information and Device Identifiable Information for such purposes and to maintain the security of the Services.

Product Improvement and Marketing: WFC LA may also use your Personal Identifiers, Contact Information, Biographical Information, Financial Information, Device Identifiable Information, and other information collected through the Services to:

• Help us improve the content and functionality of the Services;
• Better understand our users and their preferences;
• Provide user and customer support;
• Personalize experiences and product offerings on our Services; and
• Tailor payment plan offerings (if applicable).

WFC LA may also use this information to communicate with you regarding the Services and, to the extent permitted by law, to tell you about services we believe will be of interest to you.

Enforcement and Legal Obligations: WFC LA may use your Personal Information to enforce our Terms of Service [Insert hyperlink to Terms of Service], or to investigate and prevent activities that may violate our policies or be illegal, and to respond to legal proceedings and obligations.

5. How We May Share Your Information

(A) Business Transfers

In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Information may be part of the transferred assets or business. We may also share your Personal Information with any subsidiary, parent, or affiliated entity for purposes consistent with this Privacy Policy.

(B) Sale of Personal Information

A “sale” of Personal Information under the California Consumer Privacy Act (“CCPA”) is defined broadly to include selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating the Personal Information of a user to another business or third party for anything of value.

WFC LA may provide some Personal Information, including Personal Identifiers and Contact Information, to some of its sponsors and partners so that they may market products and services that may be of interest to our users. If you are a California resident and would like to opt-out of the sale of your Personal Information to our sponsors and partners, please fill out this opt-out form. We do not discriminate against you because you opt-out of the sale of your Personal Information. But, please note that if we are unable to provide your Personal Information to our sponsors or partners it may mean that you will not receive benefits provided to other users (e.g., sample products or services).

(C) Service Providers and Third Parties

We may share Personal Information and Device Identifiable Information with Service Providers, as described in Section 3.

In addition to the information sharing described in Section 4(B), we may share with third parties aggregated demographic information collected on or through the Services for various purposes such as user research and analysis. Aggregated demographic information does not include and is not linked to any Personal Information that can identify you or another individual person but we may use your IP addresses to verify users’ locations for various purposes, including special offers and various restrictions.

(D) User Referrals

Users may send information about our us, our affiliates, our products or the Services, to their friends and family members by using an “Email to Friend” or similar feature in the Services or in an email that we have sent them, which feature may now be available or may be available in the future. We do not and would not further contact those individuals without their consent to do so.

(E) Third-Party Marketers

With your permission, we may share your Personal Information with our marketing partners and other third parties so that they may contact you directly regarding special promotions or offers (such as subscriptions to and promotions for goods and services, including, for example, through participation in a co-sponsored sweepstakes or contests). We are not responsible for how these third parties may use your Personal Information, and such uses are subject to their own policies. If you have consented to our sharing of your Personal Information with third parties for such third parties’ marketing purposes, you can change your mind at any time and may let us know by following the instructions in Section 7.

(F) Legal Requirements

We may also share Personal Information and Device Identifiable Information under the following circumstances:

• If required by law, such as by a court order, statute, regulation or rule, through legal process, or for law enforcement purposes;
• In the event of a bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of our creditors;
• If we determine it necessary in connection with an investigation or in order to protect our legal rights; or
• In response to requests from federal, state, local or foreign law and civil enforcement agencies, such as a search warrant, subpoena or court order.

6. Communication Services and Community Features

(A) Chat Rooms, Forums, and Message Boards

The Services may make chat rooms, forums, blogs, message boards, and other community features and activities available to you and other users. If made available and you post Personal Information online, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure the security of any information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Please exercise caution when deciding to disclose Personal Information in these areas. We reserve the right (but assume no obligation) to review and/or monitor any such community features and activities on the Services.

(B) Short Message Service

We may make available a service through which you can receive messages on your wireless device via short message service (“SMS Service”). You understand that your wireless carrier’s standard rates apply to these messages. If you subscribe to one of our SMS Services, you may be required to register and provide Personal Information. We may also collect the date, time, and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service for the purpose of sending SMS messages. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information to facilitate the transaction in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. We may also contact your carrier, which may access the content of your wireless account, for the purpose of identifying and resolving technical problems and/or Service-related complaints. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience in connection therewith. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service, as well as any fees assessed by your wireless carrier. You may change your mind and unsubscribe to SMS Services at any time by following the instructions in Section 7.

7. Third-Party Advertising

We may allow other companies that are providing advertising content, social networking services, or other services on our Websites to set and access tracking technologies such as cookies on your computer. These companies may collect information about your visits to the Websites in order to measure and assess the effectiveness of online advertising and to provide and better target advertisements about goods and services of interest to you. While the information collected by these third parties from you while you are visiting our Websites is not personally identifiable, some of these third parties may also combine such deidentified information with other information they have collected from various other sources, such as their own past online and/or offline purchase information and web usage from other sites. Such other information may include Personal Information, as well as demographic and behavioral information. Those companies’ use of cookies, and the information collected, are governed by those companies’ privacy policies, not ours. Please see Section 7 for ways to opt-out of this third party advertising.

8. All Users: Your Choices and Controls

You have various choices with respect to the collection of and certain of our uses of the Personal Information we collect from you on or through the Websites or Services. If you have not consented to us using your Personal Information as described in this Privacy Policy, we will only use it to complete the transaction or provide the service or product you have requested.

If you have agreed to receive communications or solicitations from us (and signed up for an account with us), and you later change your mind, you can  contact us at hello@wfcla.co. You also may opt out of receiving all future promotional emails from us by clicking on an opt-out or “unsubscribe” link within the promotional email you receive. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your other relationship, activities, transactions and communications with us.

If you have agreed to have us share your Personal Information with third parties so that they may contact you about promotions (and signed up for an account with us), offers and other information, and you later change your mind, you can contact us at hello@wfcla.co. If you do request to have us stop sharing your Personal Information with other entities for their direct marketing purposes, such request will only apply as of the date of your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Information prior to such request. In these cases, please contact that entity directly or click on the opt-out or “unsubscribe” link that should be included within the promotional email you receive from such third party.

You may opt-out of receiving ads from network advertisers by clicking the AdChoices icon on advertisements that are sent to you, visiting the opt-out pages on the NAI website and/or the DAA website. Opting out does not prevent you from seeing ads; it simply means that network advertisers will no longer collect data for the purpose of providing you targeted ads. The DAA and NAI opt-out tools are cookie-based. They signal network advertisers so that they do not collect data online or deliver specific ads targeting you, and only affect the Internet/web browser on the computer where the cookies are installed. These opt-out tools will only function if your browser is set to accept third-party cookies.

If you delete an opt-out cookie or all your cookies from a browser’s cookie files, change web browsers or change computers, you will no longer be opted out of our data collection and ad targeting, and we may place a new cookie unless an opt-out cookie is again reset on that browser. Opting out using one browser on one computer will not opt you out using any other browser on the same or another computer.

9. California Residents: Your California Privacy Rights

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please contact us at hello@wfcla.co or write to us at: WFC LA, Inc.
11693 San Vicente Blvd., #201
Los Angeles, California 90049
Attention: CA Resident Privacy Policy Questions

Not all information sharing is covered by the “Shine The Light” requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.

If you are a California resident, then you also have certain rights under the CCPA regarding your Personal Information:

(A) Right to Opt-Out

You have the right to direct us not to sell your Personal Information (the “right to opt-out”). If you have opted-in to the sale of your Personal Information, you may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) must fill out this opt-out form.

Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize the sale of your Personal Information. You may change your mind and opt back in to the sale of your Personal Information at any time by filling out this opt-in form.

You do not need to create an account with us to exercise your opt-out rights. We will only use the Personal Information provided in an opt-out request to review and comply with the request.

(B) Right to Know

You have the right to know and see what data we have collected about you over the past twelve months, including:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• The business or commercial purpose for collecting your Personal Information;
• The categories of third parties with whom we have shared your Personal Information; and
• The specific pieces of Personal Information we have collected about you.

(C) Right to Delete

You have the right to request that we delete the Personal Information we have collected from you (and direct our Service Providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following, which may or may not be applicable here:

• Complete your transaction;
• Provide you with a good or service;
• Perform a contract between us and you;
• Protect your security and prosecute those responsible for breaching it;
• Fix our system in the case of a bug;
• Protect the free speech rights of you or other users;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
• Comply with a legal obligation; or
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

(D) Exercising Your Rights

To exercise your right to know or your right to delete (described above), please submit a verifiable user request to us as indicated in the “Contact Us” section of this Privacy Policy. Only you, or someone legally authorized to act on your behalf, may make a verifiable user request related to your Personal Information. You may only make a verifiable user request to exercise your right to know twice within a 12-month period. The verifiable user request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We will not discriminate against you for exercising any of your CCPA rights described above. Unless permitted by the CCPA, to the extent applicable, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, please note that if we are unable to provide your Personal Information to our sponsors or partners it may mean that you will not receive benefits provided to other users (e.g., sample products or services, if any).

10. Your Additional Rights in the European Economic Area

If your personal data has been collected in connection with our activities in the European Economic Area (“EEA”), you have the following rights:

• Withdrawal of Consent: If consent is the lawful basis of our processing, you have the right to withdraw any consent that you have provided to us to process your personal data.
• Access: You have the right to access your personal data.
• Rectification: You have the right to rectify inaccurate personal data.
• Erasure: You have the right to have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there is no other legitimate grounds for processing it or you consider that it has been unlawfully processed.
• Restriction: You have the right to have the processing of your personal data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.
• Data Portability: You have the right to have certain personal data you provide to us transferred to another company in a machine-readable format.
• Objection: You have the right to let us know that you object to the further use or disclosure of your personal data for certain purposes.

In order to exercise any of these rights, or for more information, please use the contact details specified in Section 16. Please note that these rights are subject to certain preconditions and qualifications under applicable law.