PRIVACY POLICY

Last Modified: May 23rd, 2019

333 Consulting Inc. (operating as 'The Idea Collective') provides this Privacy Policy as a part of our Master Services Agreement or our online Terms of Service (the “Terms of Service”) to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our Services. This Privacy Policy applies to all information that you provide to us through our websites as a part of the Services we provide. 

This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy wherever it may appear on our sites, and give you notice that the Privacy Policy has been updated. 

Your continued use of any Services following any changes to this Privacy Policy will be considered your acceptance to our changes. You should consult this policy regularly for any changes, and it is your responsibility to become aware of and understand them. For the purposes of this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally. 

 NOTICE TO E.U. & E.E.A. RESIDENTS: Our use of your information is instead subject to the “Privacy Notice for EU & EEA Residents” which supersedes this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Master Services Agreement/Terms of Service. 

 INFORMATION, COLLECTION, AND ITS USE
 We collect information to provide and improve our sites, our features and content, to administer your account, to provide the Services, and to enable users to navigate our sites. This information can be personally identifiable, non-identifying, and include information relating to your device and activity on our sites. Please see the “What Kinds of Information Do We Collect” for more details on what is being collected. 

 We collect the content and information you provide when you use the Services. For example, we collect the content and information you provide when you use our Services, including for account registration, create, share, or request feedback, or message and communicate with others. This includes information about the content you submit, such as its creation date and subject, and your viewing preferences, such as whose profiles you visit and how you interact with our sites. Depending on your privacy settings, we collect information about your computer and other devices you use to take part in the Services. We may associate device data to provide consistent Services, and to provide a secure environment for users. This can include collecting your device identifiers, location data, and IP address to verify registered users.

 Depending on your permissions and third-party privacy policies, we may also receive information about you and your activities from our third-party partners, such as information a partner collects as part of jointly-offered services. This Privacy Policy does not apply to collection or practices of third-parties that we do not own or control, including third-party providers used in connection with the Services. While we attempt to only work with third-parties that share our policies, we cannot take responsibility for the policies of third-parties. If we work with any third-parties with data and information policies that are different than our own, we will notify you before those policies affect you. Regardless, we strongly encourage you to review third-party privacy policies before using their services or sharing your personal information. 

 WHAT KINDS OF INFORMATION DO WE COLLECT? PERSONALLY IDENTIFIABLE INFORMATION
 In the course of using the Services, we may ask you to provide us with, or grant us access to, or permission to obtain, Client Data that can be used to contact or identify you. This Client Data may include, but is not limited to, your legal name, email address, phone number, sex/gender, date of birth, and billing or shipping address information (your "Personal Information"). We collect Personal Information in connection with your registration to form an account, and to participate in certain Services. We also use your Personal Information to contact you with newsletters, email updates, marketing or promotional materials and other information that may be of interest to you.

 If at any time you decide you no longer wish to receive such communications from us, please unsubscribe from further messages from any “Unsubscribe” function we provide, update your account's "Notifications" settings, or write to us at [[email protected]]. We may also collect Personal Information about you, such as your name and email address, when you provide feedback on the Services. If you provide us with Personal Information about your contacts, such as to invite your contacts to take part in the Services, we will only use this information for the specific reason we requested, and you provided, the information. 

 NON-IDENTIFYING INFORMATION
 We also collect other information that you provide as part of registration and your use of certain Services, such as your ZIP code, geographical data, birth month or day (but not both), and individual preferences ("Non-Identifying Information"). Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, by combining your ZIP code with your street address) in a way that enables you to be identified. Those same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information, such as your viewing preferences.

 We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) to provide the Services, send you information about our sites or other Services, and to respond to and administer your inquiries. If we collect your Personal Information to provide a specific Service we will only use that information to provide the Service, and will not share that information with any third-party, including our third-party providers, except as necessary to provide the Service and as you agree under this Privacy Policy. We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to provide you with a better or more personalized user experience, to improve the quality and value of the Services, and to analyze and understand how our Services are used. 

 LOG DATA
 When you visit our sites, regardless of whether you are a registered user or a non-registered visitor, our servers automatically record information that your browser sends about your visit ("Log Data"). Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, or the webpage you were visiting before you came to our site, pages of our site that you visit, the time spent on those pages, information you search for on our site, access times and dates, and other statistics. We use this information to monitor and analyze use of our sites and its technical administration, to increase site functionality and user-friendliness, and to better tailor it to our visitors' needs. 

For example, some of this information is collected so that when you visit our site, it will recognize you and serve information appropriate to your interests. We also use this information to verify that visitors meet the criteria required to process their requests. We do not treat Log Data as Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information. 

 COOKIES 
 Like many website operators, we may use "cookies" to collect information. A cookie is a small data file that we transfer to your device's hard disk for record-keeping purposes. We will use cookies for two purposes. First, we may utilize persistent cookies to save your registration ID and login password for future logins to our sites. 

Second, we may utilize session ID cookies to enable certain features of our sites or Services, to better understand how you interact with our sites and to monitor aggregate usage by users and web traffic routing on our sites. Unlike persistent cookies, session cookies are deleted from your computer or device when you log off from your Account and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of our sites or certain functionalities of our Services.

 NOTICE ABOUT IDENTITY THEFT & PHISHING
 Identity theft and the practice known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, login password, or identification numbers, such as your driver’s license number or Social Security number, in a non-secure or unsolicited email or telephone communication. For more information about phishing, visit the Federal Trade Commission's website here: https://www.consumer.ftc.gov/articles/0003-phishing. 

 DISCLOSURE & TRACKING
 We do not currently respond to web browser “Do Not Track” settings that allow you to opt-out of information collection about your activities on our sites or third-party websites. 

 WHO DO WE SHARE YOUR INFORMATION WITH?
 The following list describes with whom we may share your information, including your Personal Information, and for what purposes. You may opt-out of any information disclosure by contacting us at [[email protected]]. If you choose to opt-out of any disclosure of your information, however, you may not be able to use all portions of our sites or certain functionalities of our Services. 

 REGISTERED USERS
 When you register to join our Services, you must submit Personal Information to create an Account. You can choose what other Personal Information you provide in connection with our Services that may be shared with other users. Providing this information is voluntary and you should only share as much as you would like to share with others. 

 TRUSTED PARTNERS
 We may share generic, aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with our trusted business partners, affiliates, or advertisers for industry analysis, demographic profiling and other similar commercial purposes. Any aggregated information shared in these contexts will not contain your Personal Information. We will only share your Personal Information with our business partners for specific purposes, and only after receiving your prior consent to whom and for what purposes the information is shared. 

THIRD-PARTY PROVIDERS & SUBCONTRACTORS
 We engage and utilize third-party providers, and other third-party companies and individuals to facilitate our Services, to provide certain Services on our behalf, such as payment processing services, maintenance services, and to assist us in analyzing how our Services are being used. These third-parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. LAW 
ENFORCEMENT
 We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may access, read, preserve, or disclose any information about you to government or law enforcement officials or private third-parties as we, in our sole reasonable discretion, believe is necessary or appropriate to (a) respond to, or satisfy, applicable law, regulations, claims, court orders, and legal process (including but not limited to subpoenas); (b) follow and enforce our agreements with you, or to investigate any suspected violations; (c) detect, prevent, or address fraud, security, or technical issues; (d) to protect the property, rights, or safety of the public, us, our users, or any third-party; or (e) to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. 

 PARTIES TO BUSINESS TRANSFERS
 We may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy to third-parties. 

 NO OTHER USES
Except as expressly set out in this Privacy Policy, we will not share, sell, trade, or rent any of your Personal Information to any third-party for any purpose.  
HOW TO CHANGE OR DELETE YOUR INFORMATION
 We will retain your information for as long as you have an Account, or as needed to provide a Service. All users may review, update, correct or delete their Personal Information. If you would like us to terminate your Account, to stop using your information, or otherwise makes changes to, or delete, your information in our systems, please contact us at [[email protected]] with your request. We will use commercially reasonable efforts to honor your request as soon as possible. However, we reserve the right to retain an archived copy, which is not accessible to third-parties, of your records and information as required by law, to maintain accurate business records, resolve disputes, or enforce our agreement with you. 

 HOW WE SECURE YOUR INFORMATION
We are very concerned with safeguarding your information. However, we are not in the business of providing information security, and cannot guarantee “perfect security” over your information. We do however employ commercially reasonable data collection, storage, processing practices, and security measures, such as using SSL encryption on some but not all systems to protect against unauthorized access, use, loss, alteration or destruction of your Personal Information. 

 We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on our sites as soon as commercially practicable, and without unreasonable delay, so long as those disclosures are consistent with (a) the legitimate needs of law enforcement; or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Do not provide us with your information if you are concerned with its disclosure or its security, or any of our policies described in this Privacy Policy.

NOTICE TO E.U. & EUROPEAN ECONOMIC AREA RESIDENTS
 If you are a person residing within the European Economic Area, including the E.U., Iceland, Lichtenstein and Norway, your information is subject to the General Data Protection Regulation (or, “GDPR”). Our use of your information is fully intended to fully comply with the GDPR. Please consult our “Privacy Notice for EU & EEA Residents” instead for information on your rights under the GDPR regarding your personal data. 

 NOTICE REGARDING INTERNATIONAL TRANSFER OF INFORMATION
 Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, you agree that your personal information will be transferred to the United States and processed there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. 

 LINKS TO OTHER SITES 
 Our site may contain links to other websites. If you click on another third-party link, you will be directed to that third-party's website. The fact that we link to a third-party website is not an endorsement, authorization or representation of our affiliation with that third-party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. 

OUR POLICY TOWARDS CHILDREN
 Protecting the privacy of children is especially important to us, and we strictly comply with the FTC’s Children’s Online Privacy Protection Rule (“COPPA”). Our Services are not directed to, or meant for persons under the age of 13. We do not knowingly collect or solicit personally identifiable information from children under 13, or allow them register Accounts. If we become aware that a child under 13 has provided us with Personal Information, or any user has provided information of or about any person under the age of 13, we will delete such information from our systems. Do not submit any Personal Information to us if you are under the age of 13, or any information of, or about, persons under the age of 13. If you are a parent or guardian and you become aware that your child has provided us with Personal Information without your consent, you should contact us immediately at [email protected]] to request we delete your child’s information. 

 CONTACT US If you have any questions regarding this Privacy Policy, or our practice and procedures about your information, please contact us at [[email protected]]. You may also contact us at our current mailing address and phone number at: 140 Encinitas Blvd. Suite 198 Encinitas, CA 92024