NOTICE AT COLLECTION

You should read the entire policy; however, you may use the links below to be directed to the information you are seeking or to see a summary of some key material in this Privacy Policy. 

Personal information we collect and sources of that information. We may collect personal information directly from you, using technological means, or from third parties such as our clients. Within the past twelve months, we and third parties acting on our behalf may have collected: your identifiers, such as your contact information; the content of communications when you contact us; demographic and educational information; and information about your location. We may also automatically collect information about your use of our Sites, such as IP address, the browser you use, device identifiers, and the site you reach us from and depart for.

How we use your personal information. We use information for purposes including marketing, to respond to questions or solicitations, to communicate with you, to improve our products and services, to provide services to our clients, for security purposes, and as permitted or required by law.

We share information with third parties. We may share information with other members of the Santa Margherita USA family of businesses, with third party service providers, with our business partners, with third parties for their marketing purposes, if required by law or to protect ourselves, or to a successor to our business in the event of a merger or sale of our assets.

You have choices about how we use your information. You can opt-out of our commercial email and have the ability to control cookies and tracking tools.

These sites are not intended for children under 16 years of age or individuals under 21 years of age. If you are the parent of a child who has provided us with personal information, you can contact us to request that we delete that personal information. We use standard security measures; however, no security measures can provide 100% protection. We cannot promise your information will be completely safe. We may transfer personal information to other countries. As a result, this information may be accessed by governments or law enforcement in these countries according to their laws. We may link to third party sites or services we don’t control. We are not responsible for the practices of these sites or services.

Please contact us if you have any questions.

PERSONAL INFORMATION WE COLLECT

During the past twelve months, we may have collected the following categories of personal information about you:

Identifiers, such as your name, mailing address, shipping address, email address, and phone number.

Characteristics of protected classifications under California or other state or federal law, such as age; gender identity or gender expression; marital status; military or veteran status; demographic information, or disability information.

The content of your communications from the information you submit, such as when you contact us, RSVP for an event, download a white paper, or submit an inquiry or job application.

Professional or employment information, such as your current company, business name, business address, and business contact information, title, or resume.

Job applicant information if you apply for a career with us. For example, you may volunteer to submit information like your gender, race, ethnicity, veteran status, education history, employment history, or disability status.  We may also collect your zip code or postal code.

Internet or other similar network activity, such as browsing and usage information. When you use our Sites, we may collect information about your interactions with the Sites, your IP address, and the browser you’re using. We may look at what site you came from, or what site you visit when you leave us. We may also collect device identifiers and your email interactions with our marketing efforts.

Financial account information, such as credit card information collected by our service providers when you make a purchase from our Sites.

Geolocation information, such as IP address or zip code.

Commercial information, such as transaction history of products you purchase on our Sites or purchase preferences.

Audio, video, and/or still images, via customer service phone call recording or when you upload content to one of our social media pages.

Sensitive personal information, such as account passwords used to access the Sites. If you enter a sweepstakes, we will ask for a copy of your driver’s license or state ID card to confirm your age and state of residence.

Inferences drawn from personal information, which are used to create a profile reflecting your preferences, characteristics, behaviors, and attitudes. We do not use sensitive personal information to infer characteristics about you for advertising purposes.

Any other information that you provide to us.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect information directly from you. For example, we may collect information when you visit our Sites, contact us, or submit an inquiry or job application.

We, and third party providers, indirectly collect information from you using online tracking tools like browser cookies and web beacons to collect information about users over time when you use our Sites. To learn more about these tools and how you can control them, please see the “Use of Cookies and Similar Tracking Technologies” and  “Your Privacy Choices” sections below.

We may also use software tools called “session replay technology”  to monitor how you interact with our Sites. The personal information collected by this technology may include which links you click on, pages and content you view, information that you type into our online forms, recordings of mouse clicks and movements, and information about your device or browser.
 
We get information about you from other parties. Our business partners, such as clients, service providers, and parent, affiliate and/or subsidiary agencies may give us information about you. Social media platforms may also give us information about you.

We combine information. For example, we may combine information that we have collected offline with information we collect online. Or we may combine information we get from a third party with information we already have to create inferences about you.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information as follows:
 

• For marketing and advertising purposes. For example, we might provide you with announcements or updates, or serve you ads about our events or services, both on our Sites, and on third party sites. We might tell you about new features or updates to our offerings. These might be third party offers or products we think you might find interesting. We might send you emails, texts, or call you by phone. To learn about your choices for these communications, read the “Your Privacy Choices” section below.
   

• To respond to requests or questions. We may use information to respond to your inquiry, job application, or feedback.
   

• To communicate with you. We might contact you about this Privacy Policy, our Terms of Use, or other aspects of our relationship with you.
   

• To improve our Sites, products, and services. We may use information to make our Sites better or enhance our product and service offerings.
   

• For security purposes. We may use your information to protect our Sites, network, business operations, and to stop activities that may violate our policies or be fraudulent or illegal. We may also use your personal information to protect our users or customers.
   

• For our business operations. We may process your information for one of our business customers. For example, we may receive personal information from business customers and use it to provide our services to them.
   

• For legal purposes. We use information as otherwise required or permitted by law, such as to comply with legal process like warrants or court orders.

HOW WE DISCLOSE, SELL, OR SHARE YOUR PERSONAL INFORMATION

We may disclose your personal information to the following recipients:
 

• Within the Santa Margherita USA family of businesses. This may include parent, affiliate, and/or subsidiary businesses and entities.
   

• To service providers, vendors, or agents that perform services on our behalf. For example, we may share personal information with the companies that operate our Sites or conduct analytics for us.
   

• To our third party business customers and partners. For example, we may share personal information with third parties who collaborate on projects or co-host events with us.
   

• To personalize our ads and marketing experiences, or to personalize our ads for current job openings, we work with ad and analytics partners, ad networks, and social media sites.
   

• To comply with the law or to protect ourselves or third parties. For example, we may share personal information to respond to a valid court order or subpoena from a government agency or investigatory body.
   

• For other reasons that we may describe to you at the time of collection or to which we otherwise obtain your consent.
   

• Any successor to all or part of our business. For example, if part of our business was sold, we may give our client and potential client list or any other personal information held by the affected portion of the business as part of that transaction.

“Sale” and “sharing” of personal information

To personalize our ads and marketing experiences, or to personalize our ads for current job openings, we work with ad and analytics partners, ad networks, and social media sites. We may also share your personal information with third parties for their own marketing purposes. These disclosures and partnerships may be considered a “sale” or “sharing” under some US laws, even when no money changes hands. The personal information we might “sell” or “share” includes: your identifiers; professional or employment information; education information; internet and online activity information; commercial information; geolocation information; financial information; and any other personal information you provide on our Sites where cookies are present. Santa Margherita USA does not sell or share the personal information of children under the age of 16.  Please visit the “Privacy Rights for U.S. Residents” section to opt-out of this “sale” or “sharing” of your personal information.

DISCLAIMER REGARDING VIDEO CONTENT

The Sites may contain video content, audiovisual content, or content of a like nature (collectively, “Video Content”). In connection with our provision of Video Content, the Sites may utilize online tracking technologies and code-based tools, including, but not limited to, Software Development Kits (“SDKs”), pixels, and cookies (i.e., advertising or analytics cookies) that track information about your activity and webpage-viewing history on the Sites (collectively, “Tracking Tools”). Tracking Tools on the Sites may result in information about your activity on the Sites being transmitted from your browser to us and third parties, which, in turn, may result in the display of targeted advertisements on third-party websites, platforms, and services, including advertisements for our content. In addition, whether Tracking Tools on the Sites result in your browser’s transmission of information to third parties depends on a number of factors that may be outside of our knowledge or control, including what third-party websites you use, what information you have provided to such third parties, and whether (and the extent to which) you have limited the use of cookies by the operators of those third-party websites, platforms, and services. Please see the section, “Use of Cookies and Similar Tracking Technologies” below for more information about our use of these tools.

FINANCIAL INCENTIVES, OFFERS, AND BONA FIDE LOYALTY PROGRAMS

This section applies when we offer you financial incentive programs, sweepstakes, or bona fide loyalty programs like discounts and special offers (collectively, “Offers”) in exchange for your personal information. In calculating these Offers, we consider the expenses related to the Offers and the value of your personal information.

You may withdraw from any of the Offers at any time by following the instructions provided. Please note that if you opt out or request to delete your personal information, we may no longer be able to provide you with the benefits of the Offers. For Offers involving your e-mail, you may unsubscribe via the “unsubscribe” link in any marketing email you have received. For all other Offers, you may follow the instructions provided with the Offers.
  
THESE SITES ARE NOT INTENDED FOR MINORS OR CHILDREN

Our Sites are meant for adults 21 years of age and over and we do not we do not knowingly collect personal information via our Sites from minors under the age of 21.
 
Santa Margherita does not knowingly collect personal information from children under the age of 16, via the Sites or offline. If you are a parent or legal guardian and think your child under the age of 16 has given us personal information, you can email us at info@santamargheritausa.com or write to us at the address listed at the end of this policy to request that we delete that personal information.

SECURITY MEASURES AND DATA RETENTION

The Internet is not 100% secure. We cannot promise that your use of our Sites will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords. You are responsible for maintaining the secrecy of your account information and all activities that occur when you are logged into your account.

We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy and in accordance with our data retention policies. We also keep information as otherwise required by law.

WE MAY TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES

Some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

By providing us with your personal information, you understand that we may transfer it outside of your jurisdiction of residence. If you do not agree to the transfer of your personal information outside of your jurisdiction of residence, do not provide us with personal information.

WE MAY LINK TO THIRD PARTY SITES OR SERVICES WE DON’T CONTROL

If you click on a third-party link, you will be taken to a platform we do not control. This Policy does not apply to the privacy practices of those third-party platforms. Read the privacy policy of other platforms carefully. We are not responsible for these third party platforms.

USE OF COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We use, and may allow certain third parties (including advertisers, third party ad networks, and other ad companies), to use cookies, web beacons, social media pixels, and other similar online tracking technologies (together, “cookies”) to provide our Sites, serve advertisements on the Sites, and to improve the performance of our advertising across websites. A cookie is a text file that is placed on your hard drive to collect information about your activities on a website.

The types of cookies used on our Sites can be categorized as follows:

•  Essential or Strictly Necessary Cookies are essential to our Sites, and allow you to navigate and use their features. They also help authenticate users and prevent fraudulent use of your account.
   

• Performance and Analytics Cookies, which are sometimes called “analytics cookies,” enable us to improve our Sites by seeing which areas and features are most popular and to count the number of computers or mobile devices accessing our Sites.
   

• Functional Cookies allow us to personalize and improve your experience by recording your preferences, which allows you to visit our Sites without re-entering your username and/or password.
   

• Targeting or Advertising Cookies are used by us and third parties to deliver ads we or third parties believe are more relevant to you and your interests, to improve the performance of our advertising across the Internet, and to limit the number of times that you see an ad on our Sites.
   

You can control certain cookies and tracking tools on our Sites via the cookie banner on the relevant Site.
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You may be able to block or remove cookies through your browser settings. You can delete cookies by going to the preferences, tools, or options menus of your browser.