Last Modified: November 22nd, 2016
2. Information we collect
We collect information in two ways, directly from your input into the Platform, and automatically through the Service.
a. Information provided by you
The verification process requires you to submit Information in order to verify your age and identity (the "Verification Process"). We collect any information you provide to us by filling in forms on our Platform.
The information listed below is used to complete the Verification Process. Usually we are able to complete the Verification Process by collecting the following information:
- Your first and last name.
- Your date of birth.
- Your address, including city, state, zip/postal code, and country.
In the event that we are unable to verify you using this information, we will collect a picture of your federally recognized photo I.D., such as your driver’s license (an “ID”). To send us your ID, you can upload a file from your computer or take a picture within your browser if it is supported.
If you choose to use your mobile phone to complete the Verification Process, we will collect your phone number in order to send you a link to continue the Verification Process.
b. Information collected automatically
We collect non-personally identifiable information automatically for the primary purpose of customizing the Platform and Service, understanding how they are used, and preventing misuse.
For example, when you use access the Platform, we automatically record information from your device, its software, and your activity using the Platform. This may include, but is not limited to the date and time of your access to the Platform, your device’s internet protocol (“IP”) address, browser type, the web page visited before you came to our website, locale preferences, identification numbers associated with your devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning files included in the Information submitted to us, and other interactions with the Platform.
Some devices allow applications to access real-time location-based information (for example, GPS or sensor data from your device that may provide information on nearby Wi-Fi access points and cell towers). We do not collect such information from your mobile device at any time as of the date this policy went into effect, but may do so in the future with your consent to improve the Service. Some of the information we collect from a device, for example IP address, can sometimes be used to approximate a device’s location. Finally, some browsers share your location information (either the location registered with your account or gleaned from other geo-location methods) with sites you visit and we may obtain location information about you in this way. If you do not wish us to receive this information, please configure your browser not to share it.
3. Use of your Information
The information collected through the Verification Process is used for the Verification Process, to communicate with you, and to customize your experience. We may retain all information collected in order to facilitate future Verification Processes, with the exception of your ID, which is deleted as soon as the Verification Process is complete. If you do not wish us to retain your personally identifiable information, you can send an e-mail to email@example.com to request that we delete that information from our records. We may, however, retain your information even if you instruct us to delete it, if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Agreement. Information stored in routine backups may also be retained for the period those backups are retained in the ordinary course of business.
4. Sharing or Disclosing your Information
Your Information may be disclosed to our employees, vendors, contractors, consultants and other service providers who need access to such information to carry out work on our behalf, at our direction and subject to the terms of this policy, including a third-party identity verification provider. The results of the Verification Process, as well as some or all of your Information may also be shared with the Merchant as part of the Verification Process. We also may share your information with your consent and at your direction.
If you submit a photo ID to our Service, it will be deleted as soon as the Verification Process is complete and will not be shared with any person except for our authorized employees or contractors.
Automatically collected non-personally identifiable information may be aggregated and disclosed without restriction. We may share aggregated, non-personally identifiable information publicly. For example, we may share information publicly to show trends about the general use of the Service with the press, in our marketing materials or with our business partners. We may collate or connect non-personally identifiable information with your personal information, in which case the resulting personally identifiable information will be treated as personal information.
We use reasonable methods, consistent with industry practices, to protect the confidentiality of your information, including administrative, physical and technical methods. Information you submit to or receive from our Service is sent using an encrypted TLS (SSL) connection.
No method of transmission over the internet is completely secure, therefore we cannot guarantee the security of your information.
6. Third-Party Sites
7. Our Policy Toward Children
The Service is not directed or available to persons under 18. We do not knowingly collect information from children under 18. If a parent or guardian becomes aware that his or her child has submitted Information in violation of our policies and has provided us with information without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under 18 has provided us with Information, we will take steps to delete that Information from our records, subject to any retention reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce the Agreement.
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any personal information with third parties for their direct marketing purposes.
10. Contacting Us