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Privacy & Security

OVERVIEW

Effective Date: January 1, 2019 Last Modified Date: January 6, 2019

THIS PRIVACY POLICY DESCRIBES

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.

Please note that this Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message, other electronic message, or offline.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY

When you submit information to or through the Services, you consent to the collection and processing of your information as described in this Privacy Policy.

By using the Services, you accept the terms of this Privacy Policy and our Terms of Service and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our Terms of Service. The Terms of Service contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action.

This Privacy Policy is incorporated into and made a part of our Terms of Service.

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE ANY OF THE SERVICES.

The Effective Date of this Privacy Policy is set forth at the top of this Policy. Whenever possible, we will provide you with advance written notice of our changes to this Privacy Policy. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

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.

Certain Personal Information, such as information about personal health or finances, is characterized as Sensitive and subject to stricter regulation than other personal information. Before providing it to use, we urge you to carefully consider whether to disclose your Sensitive Personal Information to us. If you do provide Sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Policy.

“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

Whether we collect certain types of information and how we process it depends on how you use and access the Services. Some information is collected automatically through use of cookies and similar data collection tools. We collect information about you in the following ways:

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.

Connect with social media though the Services. The Services may offer you the ability to use Facebook Connect or other social media services (collectively, “social media”) in conjunction with certain Services. When you access the Services through your Facebook or other Social Media account, the Services may, depending on your privacy settings, have access to information that you have provided to the Social Media platform. We may use this information for the purposes described in this Privacy Policy or at the time the information was collected. When you associate your social media account with your account and authorize us to have access to this information, you agree that we may collect, use and store the information provided by social media services as described in this Privacy Policy.

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

Third parties that assist us with our business operations also collect information (including Personal Information and Usage Data) about you through the Services and share it with us. At times third parties assist in processing orders or in helping us detect and prevent fraud. For example, we use Google Analytics to help us understand our customer’s interactions with the Site. You can read more about the privacy policy of Google at this link. If you want to opt-out of Google Analytics, you can download and install a browser add-on that can be found at this link.

We may combine the information we collect from you with information from other sources and use the combined information as described in this Privacy Policy.

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.

During corporate changes. We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.

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.

YOUR RIGHTS

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) 277-1429.

LINKS TO THIRD PARTY SERVICES

The Services may contain links to third-party websites and services (“Third Party Services”) with which we have no affiliation. A link to any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to its privacy policy and practices and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

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.

ACTIONS PRINT