Reviewed on June 28th, 2023


Affirma LLC., (along with its affiliates for the purposes of this Policy, the “Company”, “we”, or “us”), has created this privacy policy for www.affirma.com (the “Site”) and affiliated sites in order to demonstrate its firm commitment to privacy. The following discloses Affirma’s information gathering and dissemination practices for the information collected through this Site. We encourage you to read this Policy before using this Site. Your use of this Site constitutes acceptance of all terms of this Policy. PRIVACY STATEMENT

I.            Types of Information Collected by Company and Uses of Such Information

A. Information Provided By You

We receive and store any information you enter on this site or which you provide to us in any other manner. Such information may include your name, postal address, telephone number, and e-mail address.

Creating an account, signing up for email communications, contacting Company customer service, engaging in a Company promotion online or instore, or as well as any other interaction with this Site will provide us with your information.

Your personally identifiable information may be used by us for all legal purposes, which may include, but are not limited to, responding to your requests, processing your transactions, for administrative purposes.

If you choose to opt-in, you may receive certain future information or communications from Company, and we may share your personally identifiable information with Company’s subsidiaries or affiliated entities (“Affiliated Entities”) for purposes of sending you information about the programs of Company or its Affiliated Entities and, occasionally, sending you advertising/promotional material from some of their advertising and strategic partners (see the Opt-In/Choice section below). We may also use your personally identifiable information for internal business purposes, such as optimizing Site experiences and analyzing and managing our businesses.

Note Regarding Use of this Site by Children

We request that children under the age of 13 do not provide personally identifiable information through the Site.

B. Demographic Information

We may also collect demographic data, such as your gender and postcode, when you provide this information to us. Demographic data may be used to tailor your experience at this Site, such as displaying the content according to your postcode.

On occasion, aggregate information that does not identify any particular user may be compiled and shared with subsidiaries and affiliates of Company, and other third parties as described in Section II below.

C. Passive Collection of Non-Personal Information (Automatic Information)

This Site often requires the use of encrypted or non-encrypted cookies. Cookies are data that a web server transfers to an individual’s computer for record-keeping purposes. Cookies are an industry standard used by most websites and help facilitate users’ ongoing access to and use of a particular website, for example by providing information used to deliver content specific to your interests and for other purposes, such as security and other account administrative functions, and which may track personal identifying information.

Cookies do not cause damage to your computer systems or files, and only the website that transferred a particular cookie to you can read, modify or delete such cookie (cookies may also be deleted by individuals through their web browser settings).

To avoid or minimize automatic information collection through the use of cookies, please refer to the help section of your browser. Please be advised, however, that declining cookies may make it difficult or impossible for you to use portions of the Site.

As part of the log-in process, this Site may use persistent cookies. Persistent cookies are cookies stored on your computer allow us, to remember information about you, such as your log-in information, so that we may enhance your experience the next time you visit the Site. You must give your permission to allow this Site to set persistent cookies. You may opt-out of the use of persistent cookies at any time.
We may also use flash cookies, also known as “local shared objects,” on this Site during the log-in process. Flash cookies are small files, similar to browser cookies, and are used to remember the Site’s settings in order to personalize the look and feel of the site. Flash cookies only collect data in the aggregate.
Session cookies may also be used during this Site’s log-in process if you register an account, in order to recognize your log-on credentials, and enhance your browsing of the Site.

The Company requires these entities to confine their use of cookies to the uses permitted by this Policy, but the Company cannot be responsible for third party uses of cookies.

The Site may use “pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “Pixel Tags”) to compile aggregate statistics about Site usage and response rates. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver advertisements for goods and services that may be of interest to you and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

D. Additional Informational Collected

Company also collects “referrers” information, IP addresses and various environmental variables.

  1. A “referrer” is information the web browser passes along to our web servers that references the URL from which you arrived at this Site.
  2. The “IP address” is a number used by computers on the network to identify your computer so that data can be transmitted to you.
  3. “Environmental variables” include, among other things, the domain from which you access the Internet, the time you spent accessing this site, the type of web browser and operating system or platform used, the Internet address of the website you left to visit this Site, the names of the pages you visit while at this Site and the Internet address of the website for which you exit Company’s Site.

E. Use of Collected Information

Company collects this information for its internal use, such as to enhance website security, to detect broad demographic trends, to assist Company in providing content tailored to your interests, and to otherwise enhance your experience on this Site. Collected information may also be shared with third parties on an aggregate and non-personally identifiable basis.

We, along with such third parties, may use both personally identifiable information and non-personally identifiable information, separately or jointly, to improve our marketing and promotional efforts, improve our products and services, better understand customer interests and preferences, and /or provide you relevant information. We may enhance or merge information that you provide with data obtained from third parties.

II.            Disclosure of Information to Third Parties
Company may share personally identifiable information, including information that you provide on the Site, with third parties as described below.

A. Affiliated Entities
We may share any information, including personally identifiable information that you provide on the Site, with our subsidiaries and affiliates worldwide, for the purposes described in Section I A (“Information Provided By You”)

B.  Strategic Partners (Third-Party Partners)
From time to time, Company may enter into a special relationship with another company that is not owned by nor affiliated with Company in order to provide additional features on this Site. These special relationships may include business partners, sponsors and sites co-branded by Company and its Strategic Partner (referred to here as “co-branded pages”). Any information, including personally identifiable information that you provide to these co-branded pages, may be shared with these third-party partners. By participating in activities or providing your information on these co-branded pages, you also consent to our providing your personally identifiable information to such third-party partners. Since these third-party partners will use your information in accordance with their own privacy practices, you should check their websites for information regarding their privacy policies.

C. Third-Party Service Providers
We may use third party service providers to help us operate our business, and this Site, or to administer activities on our behalf, such as sending emails, and order fulfillment. We may share your information with these third-party Service Providers for those limited purposes.

D.  Other Disclosures
Information, including Personally Identifiable Information) of any individual user may be shared with other companies outside Company: (i) as permitted by law, (ii) in the event of a transfer of ownership, assets or a bankruptcy of Company, (iii) where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process, or (iv) to protect the interests or safety of Company or other visitors to this Site.

E. Opting Out
You will generally receive notice when information about you might be shared with third parties, at which time you will fully be able to opt out of the sharing of such information permissible.

III.            LINKS AND THIRD PARTIES’ PRIVACY PRACTICES

This Site may contain links to other sites that are not operated by Company.

COMPANY IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF SUCH OTHER WEBSITES, INCLUDING WEBSITES OPERATED BY AFFILIATED ENTITIES OF COMPANY.

We provide such links only as a convenience and the inclusion of a link on the site does not imply endorsement of the linked site by Company. If you provide any personally identifiable information through any such third-party website, your transaction will occur on such third party’s website (and not on this site) and the personally identifiable information you provide will be collected by, and used in according with the privacy policy of, that third party. Company recommends that you review the privacy policy of any third-party websites arrived at from links on this Site.

IV.            General Data Protection Regulation (GDPR)

Affirma adheres to applicable data protection laws in the European Economic Area, which, if applicable to you, include the following rights:

  1. Where processing of Personal Data is based on your consent, you have a right to withdraw consent at any time for future processing
  2. You have a right to request access to, rectification, or erasure of your Personal Data, or to transfer or receive a copy of your Personal Data in a usable format
  3.  You have a right to object to the processing of your Personal Data under certain circumstances
  4.  You have a right to lodge a complaint with an applicable data protection authority

You must contact your Company if you have questions or seek to exercise any of these rights.

V.                  CCPA (California Privacy Act)

Because Affirma values your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute any personal information to outside parties without your consent except as stated in clause 7.

As part of the California Online Privacy Protection Act, all users of our website may make any changes to their information at any time by contacting us at privacy@affirma.com

VI.               Children’s Online Privacy Protection Act Compliance

Affirma is in compliance with the requirements of the Children’s Online Privacy Protection Act. We will not intentionally collect any information from anyone under 13 years of age. Our website, products and services are all directed at people who are at least 13 years old or older.

VII.              SECURITY
This Site has security measures in place to help protect against the loss, misuse and alteration of the information under its control. Company employs reasonable security measures consistent with standard industry practice to help protect against public access to information collected on and used by Company at this site. Some of your personally identifiable information and account activity is also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password.

VIII.            OPT-IN/CHOICE
This Site may provide you with the opportunity to opt-in to receive marketing communications from Company. You may also opt-out of marketing communications at any time by clicking the “unsubscribe” link in the body of the communication. However, regardless of your opt-in preferences, Company may still at times need to send program e-mails for administrative reasons.
Company also gives you convenient methods for removing your information from our database so as not to receive future communications or to close your account. You may:
• contact us on the website;
• call 425 880-9985, Monday through Friday 10am – 4pm PST
or you may send mail to the following postal address:
Affirma’s Marketing Department
3380 146th Place SE #200
Bellevue, WA 98007
privacy@affirma.com


Please note, changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personally identifiable information removed from our database. We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personally identifiable information, we may need to retain certain information for record-keeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. We also reserve the right, from time to time, to re-contact former users of the site for important administrative purposes. Finally, we are not responsible for informing third parties (including without limitation our third party-service providers or strategic partners) with whom we have already shared your personally identifiable information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities. We will, however, upon request, do our best to inform you of which third-party service providers or strategic partners may have obtained your information from us.

IX.                UPDATES TO THIS PRIVACY POLICY
Company reserves the right to make changes in this Privacy Policy. Due to the fast pace of this industry, these terms may change frequently, and any changes will take effect immediately upon posting. For your convenience, the last revised date of the current policy will be posted at the top of this page. Also, Company will do its best to advise of any major policy changes via email, but the effectiveness and enforceability of updated terms shall not be dependent upon actual or constructive notice. By continuing to use the Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, please do not continue using the Site.

X.                  GOVERNING LAW
This Privacy Policy is governed by the laws of the State of Washington, USA, without regard to its choice of law provisions. Any and all disputes over this Privacy Policy shall be heard in a court of competent jurisdiction within the state of Washington.

XI.                CONTACTING AFFIRMA COMPANY
If you have any questions about this Privacy Policy or the practices of this Site, you may contact:
Affirma
Seattle/Bellevue Office:
3380 146th Place SE #200
Bellevue, WA 98007
privacy@affirma.com
(425) 880-9985