Privacy & Security
Effective Date: January 1, 2019 Last Modified Date: January 6, 2019
Information that we receive from you when you interact with the services [the “Services”] provided by Pepper.
How we use and process the information that we receive.
If and why Personal Information may be disclosed to third parties.
Your choices regarding the collection and processing of your Personal Information.
TYPES OF INFORMATION WE COLLECT
We collect various kinds of information that you provide to us as well as information we obtain from your use of the Services. Some of the types of information that we may collect include:
“Personal Information” —information associated with or used to identify or contact a specific person. Personal Information includes: (1) contact data (such as email address, telephone number and employer); (2) demographic data (such as gender, date of birth and zip code); and (3) certain Usage Data (defined below), such as IP address.
“Usage Data” —information about an individual's online activity that, by itself, does not identify the individual, such as:
technical information, including your browser type, internet service provider (ISP), IP address, time zone, operating system and webpages visited;
information about what you've searched for and looked at while using the Services;
metadata, which means information related to items you made available through the Services, such as the date, time or location that a shared photograph or video was taken or posted.
"Location Data” is a category of Personal Information collected about the location of a mobile device or computer, including:
the location of the mobile device or computer used to access the Services derived from GPS or Wi-Fi use; the IP address of the mobile device or computer or internet service used to access the Services,
other information made available by a user or others that indicates the current or prior location of the user, such as information that you or others post indicating your location or geotag information in photographs.
HOW WE COLLECT INFORMATION
From You. We collect information from you when you:
Use the Services. We collect Personal Information from you when you create an account to use one of the Services, contact us for help or information or otherwise voluntarily provide your Personal Information. We collect the information and content that you submit to us, such as when you enter comments or submit a review.
Initiate a purchase or complete a transaction. We collect the Personal Information that you provide when purchasing products, which include your name, billing address, shipping address, credit card information, email address, and phone number.
FROM OUR BUSINESS PARTNERS AND SERVICE PROVIDERS
USAGE DATA. WE ALSO AUTOMATICALLY COLLECT USAGE DATA WHEN YOU INTERACT WITH THE SERVICES
One way we collect data is from cookies and other data collection tools. We, along with the service providers that help us provide the Services, use small alphanumeric files called cookies, which are small computer files sent to or accessed from your web browser or your computer's or tablet's hard drive that contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Services. Cookies are not themselves personally identifiable but may be linked to Personal Information that you provide to us through your interaction with the Services. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.
Cookies help us improve the Services by tracking users' navigation habits and storing users' password, customizing users' experience with the Services; enabling us to analyze technical and navigational information about the Services; and helping to detect and prevent fraud.
We also use other cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “data collection tools,” to help improve your experience with the Services. For example, data collection tools help us remember users to personalize your return visits, make the Services more relevant to them, and to make checkout more efficient.
The Services also may use data collection tools to collect information from the device used to access the Services, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.
Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers (including some mobile web browsers) provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user's computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services.
HOW WE USE YOUR INFORMATION
We may use the information we collect for any of the following purposes:
to provide the Services to you;
to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the provision of the Services;
to communicate with users, such as to provide purchase confirmations or product information;
to better understand how users access and use the Services, for the purposes of trying to improve the Services and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users' usage of the Services;
to help us develop our new products and services and improve our existing products and services;
to provide users with advertising and direct marketing that is more relevant to you;
to enforce our Terms of Service or other applicable policies; and
to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services.
Please note that, in order to provide you with a better experience and to improve the Services, information collected through the Services may, subject to user privacy controls (if available), be used in an aggregated or individualized manner.
For example, personal information collected during use of one of the services may be used to suggest particular content that can be made available to the user on another of the Services or be used to try to present more relevant advertising in another of the Services.
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
We may share and disclose information as described at the time information is collected or as follows:
When you consent. We may share Personal Information with third parties if you have given us your consent to do so.
To perform services. We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users, such as to process orders. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Services. We also may offer users the opportunity to share information with friends and other users through the Services.
With third party service providers performing services on our behalf. We share information, including Personal Information, with our service providers to perform the functions for which we engage them (such as hosting and data analyses or interest-based marketing). We may share information as needed to operate other related services.
For legal purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.
In aggregated form. We may share Personal Information about you in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users like you interact with our services.
INFORMATION STORAGE AND SECURITY
We retain information as long as it is necessary and relevant for our operations. We also retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, collect any fees owed, and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies.
We employ industry-standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.
It is important to us that you are able to access and review the Personal Information we have about you and make corrections to it or delete it, as necessary. You can visit your account to manage and correct the information we have on file about you. If you have any questions about how to access your Personal Information, please contact us at (702) 329-4400.
LINKS TO THIRD PARTY SERVICES
DISCLAIMER: NOT CHILD-DIRECTED
The Services are not intended for use by children. If you are under the age of majority in your place of residence, you may not use the Services.
Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services and subsequently we will delete that information.
18 U.S.C. § 2257 COMPLIANCE
Visual depictions displayed on the webpages provided by the Services do not consist of depictions of actual sexually explicit conduct as defined in 18 U.S.C. § 2256, but merely depict non-sexually explicit nudity or are depictions of simulated sexual conduct. Therefore, the visual depictions are exempt from the provisions of 18 U.S.C. § 2257 and 28 C.F.R. § 75. All models, actors, actresses, and other persons that appear in any visual depiction on the webpages provided by the Services were at least 18 years of age when the visual depictions were created.
We are not the primary producer (as that term is defined in 18 U.S.C. § 2257 and 28 C.F.R. § 75) of any of video products or of any photographs on packaging of products offered for or linked through the Service’s website, which have been produced by primary producers, such as manufacturers, creators, producers, or studios. The custodian of records for each of these primary producers are responsible for storing the original records pursuant to 18 U.S.C. § 2257 and 28
EU/SWISS PRIVACY SHIELD CERTIFICATION
We comply with the EU-U.S. Privacy Shield framework and the Swiss-U.S. Privacy Shield framework, as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. We have certified that we adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement, and liability. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ and https://www.privacyshield.gov/list.
Any personal information collected about EU visitors through the Services is processed in the United States by us or by a party acting on our behalf. When you provide personal information to us through the Services, you consent to the processing of your data in the United States. The Services are hosted in the United States.