- our surveys and other research activities;
- our retail “popup” store;
- orders that we fulfill;
- our promotions, sweepstakes, and contests;
- our marketing activities, including when you sign up for our newsletters; and our social media accounts.
We refer to our activities described above collectively as the "Service".
As you refer to this policy, here are a few things to keep in mind:
- This Site is not intended for children under 13 years of age. We do not knowingly solicit information from, or market to, children under 13 years of age.
- Wireless service providers, Internet service providers, device manufacturers and/or social media platforms may have their own privacy notices that are different from this one for the information they may access through your use of the Sites. We encourage you to read their privacy notices as the collection, uses and sharing of information by those third parties may be different than Citi.
- Our mobile, social media, or other services, sites, pages or materials may have additional terms about the privacy or use of your information. Please review the privacy notice for the specific Site/Service you are using.
Table of Contents
- What Personal Information Does the Fifteen Percent Pledge Collect?
- Cookies and Similar Technologies
- How the Fifteen Percent Pledge Uses Your Personal Information
- How the Fifteen Percent Pledge Shares Your Personal Information
- Your Choices
- Retention, Location and Security of Your Personal Information
- Accuracy of Personal Information
- Important Information for California Residents
1. What Personal Information Does the Fifteen Percent Pledge Collect?
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact Data, such as your first and last name, email address, billing and mailing addresses, and phone number when you purchase products or services from us (including at an 15PP retail store or through our website), contact us through email, or when you create an online account with us.
- Profile Data for businesses, such as your username and password that you set to establish an online account with us, details about your business (like year founded, revenue, types of products and/or services offered, contact information, founder background, headquarters location, retailer presence), photos, links to your profiles on various third-party sites including social networks, interests, preferences, and information about your participation in our events, promotions, sweepstakes, contests, or surveys.
- Communications that we exchange or you share or publish, including when you communicate with us with questions, feedback, or otherwise, our staff team, and on social media, such as through direct messages or public posts.
- Research Data that you provide when you agree to participate in our surveys or research activities, such as your survey responses, profession, interviews, workshops, and audio and/or video that we record about you or captures of your device’s screen in relation to such surveys and research activities.
- Marketing Data, such as your preferences for receiving communications about our products, services, events, promotions and newsletters and similar messages, and details about how you engage with our communications.
- Job Application Data, such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.
Third-Party Sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public Sources, such as social media platforms, publications, and news sites.
- Business and Marketing Partners, such as marketplaces including Instagram, joint marketing partners, and event co-sponsors.
- Data Providers, such as information services and data licensors that provide demographic and other information about our users.
- Users of the Service, who can purchase products or services for others, share a product or article with others, refer a friend, or otherwise share contact information of others with us.
- Third-Party Platforms, such as social media accounts such as Facebook, that you use and choose to connect to the Service. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
Automatic Data Collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services, such as:
- Device Data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online Activity Data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Photos from our stores and events.
2. Cookies and Similar Technologies
3. How the Fifteen Percent Pledge Uses Your Personal Information
We use your personal information for the following purposes or as otherwise described at the time we collect it:
To Provide Services. We use your personal information to:
- provide, operate and improve the Service and our business;
- establish and maintain your user profile on the Service, including:
- tracking your orders and shipments and sending you reminders of items left in your shopping cart;
- creating public profiles with limited background information for businesses who sign up for the Business Equity Community;
- remember devices from which you have previously logged in;
- communicate with you about the Service, including by sending announcements, updates, newsletters, and support and administrative messages; and
- provide support for the Service, respond to your requests, questions and feedback, including through Instagram, evaluate your satisfaction with the Service and to otherwise administer our relationship with you.
We may combine your personal information collected through various sources, including information collected at our retail store and through our website, and information obtained from other sources (like Shopify) such as to enhance and personalize your shopping experience on our websites and to facilitate product returns.
Administrative tasks. We may use your personal data to develop new Services and products, ensure internal quality control, communicate with you about our Services and products, process applications and transactions, work with Third Parties to process payment for products purchased or services rendered.
Research and Development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into de-identified or anonymous data by removing information that makes the data personally identifiable to you. We may use this de-identified or anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. For example, if we learn that most users use mobile devices, we might wish to expand on that feature.
Marketing and Advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes, except that such sharing with third parties does not include sharing of personal information collected through our short code text messaging programs without your consent:
- Direct Marketing. We may send you Pledge-elated or other direct marketing communications as permitted by law. You may opt-out of our marketing communications by emailing us at firstname.lastname@example.org.
Manage Recruiting and Process Employment Applications. We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
Compliance and Protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety, security or property (including by making and defending legal claims and security monitoring in our stores);
- audit our internal processes for compliance with legal and contractual requirements and internal policies; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
4. How the Fifteen Percent Pledge Shares Your Personal Information
Suppliers and Service Providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as IT, hosting, payment processing services, customer relationship management and support, print and mail fulfillment, order fulfillment and shipping, data/document storage and management, email delivery, marketing, analytics, fraud detection, event management services, promotions, sweepstakes, contests and surveys).
Professional Advisors. Professional advisors, such as lawyers, accountants, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and Others. Law enforcement, government authorities, courts, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business and Marketing Partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
5. Your Choices
You have the following choices with respect to your personal information.
Access or Update Your Information. If you have registered for an account with us, you may review and update certain account information by logging into the account.
Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://allaboutcookies.org/. We use Google Analytics, including the Google signals feature, to help us understand user activity and patterns on the sites. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookiesand about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.
Declining to Provide Information. We need to collect personal information to provide certain services, such as your address to ship a product. If you do not provide the information requested, we may not be able to provide those services.
Third-Party Platforms. If you choose to connect to the Service through your social media account, such as Facebook, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. We do not control those mechanisms and even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
6. Retention, Location and Security of Your Personal Information
We employ reasonable safeguards - including administrative, technical and physical measures - appropriate to the sensitivity of the personal information in its possession or under its control in order to protect that information from unauthorized access, collection, use, disclosure, disposal, or similar risks. While the Pledge uses reasonable efforts to protect your information, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and therefore, the Pledge cannot guarantee absolute security of your personal information.
7. Accuracy of Personal Information
You can help us maintain the accuracy and completeness of your information (including your Pledge website account information) by notifying us of any changes to your information. You may update your Pledge profile information through our website.
The Fifteen Percent Pledge does not knowingly collect personal information from children who are under 13 years of age without the consent of their legal guardian. Please immediately contact us at email@example.com if you believe that we have unintentionally collected personal information from a child under 13 years of age without the consent of their legal guardian. If the Pledge learns that it has inadvertently collected personal information from a child under 13 years of age without the consent of their legal guardian, the Pledge will use reasonable efforts to delete that information from its systems (except to the extent that retention of the personal information is required or permitted by applicable law).
The Fifteen Percent Pledge may use and disclose your personal information to administer and process your application for employment with the Pledge and related matters.
Contacting the Pledge regarding privacy concerns
11. Important Information for California Residents
Scope. This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA or information we collect from you in the course of providing services to you or receiving services from you where you are an employee, controlling owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
Your California Privacy Rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
- Opt-out of sales. You can opt-out of any sale of your Personal Information.
Right to information, access and deletion. You may exercise your right to information, access or deletion by:
We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. To verify your identity, we may require government identification, a declaration under penalty of perjury or other information. You may designate an authorized agent to make a request on your behalf pursuant to California Probate Code Sections 4000-4465. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government-issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Personal Information that we collect, use and disclose