Pep Promotions is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the Pep Promotions site and governs data collection and usage. By using the Pep Promotions site, you consent to the data practices described in this statement. California residents should refer to the California Consumer Privacy Rights section for rights and disclosures specific to California.

Collection of your Personal Information

Pep Promotions collects personally identifiable information, such as your email address, name, home or work address or telephone number. Pep Promotions also collects demographic information such as your ZIP code, age, gender, preferences, interests and favorites.

There is also information about your computer hardware and software that is automatically collected by Pep Promotions. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Pep Promotions for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Pep Promotions site.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Pep Promotions public message boards, this information may be collected and used by others. Note: Pep Promotions does not read any of your private online communications.

Pep Promotions encourages you to review the privacy statements of websites you choose to link to from Pep Promotions so that you can understand how those websites collect, use and share your information. Pep Promotions is not responsible for the privacy statements or other content on websites outside of the Pep Promotions and Pep Promotions family of websites.

Use of your Personal Information

Pep Promotions collects and uses your personal information to operate the Pep Promotions website and deliver the services you have requested. Pep Promotions also uses your personally identifiable information to inform you of other products or services available from Pep Promotions and its affiliates. Pep Promotions may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Pep Promotions does not sell, rent or lease its customer lists to third parties. Pep Promotions may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Pep Promotions may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Pep Promotions, and they are required to maintain the confidentiality of your information.

Pep Promotions does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Pep Promotions keeps track of the websites and pages our customers visit within Pep Promotions, in order to determine what Pep Promotions services are the most popular. This data is used to deliver customized content and advertising within Pep Promotions to customers whose behavior indicates that they are interested in a particular subject area.

Pep Promotions websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Pep Promotions or the site; (b) protect and defend the rights or property of Pep Promotions; and, (c) act under exigent circumstances to protect the personal safety of users of Pep Promotions, or the public.

Use of Cookies

The Pep Promotions website uses "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Pep Promotions pages, or register with Pep Promotions site or services, a cookie helps Pep Promotions to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Pep Promotions website, the information you previously provided can be retrieved, so you can easily use the Pep Promotions features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Pep Promotions services or websites you visit.

Security of your Personal Information

Pep Promotions secures your personal information from unauthorized access, use or disclosure. Pep Promotions secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

California Consumer Privacy Rights

The California Consumer Privacy Act of 2018 (“CCPA”) provides California consumers specific rights concerning their personal information, including, the right to request that Pep Promotions disclose what personal information Pep Promotions collects, uses, discloses, and sells. This section describes your rights and how you may exercise those rights as well as describes how Pep Promotions and third parties handle your personal information.

You or your authorized agent can request: 1) a disclosure of your personal information Pep Promotions collects, uses, discloses, or sells; 2) to delete your personal information Pep Promotions collects, or maintains; and 3) to opt-out of the sale of your personal information. If you choose to submit a request through an authorized agent, Pep Promotions will require proof that the authorized agent has your written permission to submit a request on your behalf. Additionally, Pep Promotions may require you to verify your identity with Pep Promotions through the verification process detailed below.

If you choose to exercise these rights, Pep Promotions will not discriminate against you because of it. However, Pep Promotions may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive Pep Promotions offer will reasonably relate to your personal information's value and will be described to you in writing. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

You have the right to request that Pep Promotions disclose certain information to you about Pep Promotions’ collection and use of your personal information over the past 12 months. Once Pep Promotions receive and confirm your verifiable consumer request, Pep Promotions will disclose to you:

  • The categories of personal information Pep Promotions collected about you.
  • The categories of sources for the personal information Pep Promotions collected about you.
  • Pep Promotions’ business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom Pep Promotions shares that personal information.
  • The specific pieces of personal information Pep Promotions collected about you.
  • If Pep Promotions sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You also have the right to request that Pep Promotions delete any of your personal information that Pep Promotions collected from you and retained, subject to certain exceptions. Once Pep Promotions receives and confirms your verifiable consumer request to delete, Pep Promotions will delete (and direct Pep Promotions’ service providers to delete) your personal information from Pep Promotions’ records, unless an exception applies.

You may submit a request to know or request to delete, free of charge, online through Pep Promotions’ interactive web form https://www.peppromotions.com/Contact-Us , or   through Pep Promotions’ phone number 513-826-0101 or in-person at applicable events. Note that for requests to delete, Pep Promotions will require you to separately confirm that you want your personal information deleted. To verify your identity, Pep Promotions may require you provide your name, email and/or address. For some requests, Pep Promotions may also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. Once submitted, you will receive an email within 10 days that Pep Promotions will use to verify your identity and provide confirmation of your request. Pep Promotions will respond to your request to know or request to delete within 45 days from the day Pep Promotions receives the request. If necessary, Pep Promotions may extend the time period to a maximum total of 90 days from the day Pep Promotions receives the request. In such case, you will receive an email notifying you of the extension and explaining the reason for the extension. Any disclosure in response to a request to know will cover the 12-month period preceding Pep Promotions’ receipt of the request and will be delivered in a readily useable format, by mail or electronically at your option.

Your request to know or request to delete may be denied for any reason allowable under the CCPA. For example, Pep Promotions may deny your deletion request if retaining the information is necessary for Pep Promotions or Pep Promotions’ service provider(s) to:

  • Complete the transaction for which Pep Promotions collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of Pep Promotions’ ongoing business relationship with you, or otherwise perform Pep Promotions’ contract with you.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it or any other purpose permitted by the CCPA.

Similarly, Pep Promotions may deny requests:

  • For specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that personal information, your account with Pep Promotions, or the security of Pep Promotions’ systems or networks.
  • To access or delete information that is de-identified.
  • If your identity cannot be verified to a degree of certainty required by the CCPA.
  • From an authorized agent that does not submit proof that they have been authorized by the consumer to act on the consumer’s behalf.

Pep Promotions does not, and will not, sell your personal information. However, generally speaking, if you are 16 years of age or older, you have the right to opt-out from a sale of your personal information by a business. A business cannot sell the personal information of consumers it actually knows are less than 16 years of age, unless it receives affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and less than 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Pep Promotions collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (for the purposes of this section, “personal information”). In particular, Pep Promotions has collected the following categories of personal information from California consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

 

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.


Audio, electronic, visual, thermal, olfactory, or similar information.

 

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

YES

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Pep Promotions may obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you or your agent.  For example, through surveys submitted by you to Pep Promotions.
  • Indirectly from you or your agent. For example, through information Pep Promotions collects in the course of providing services.
  • Directly and indirectly from activity on Pep Promotions’ websites. For example, through posting on public message boards.

Pep Promotions may use or disclose the personal information Pep Promotions collects for one or more of the following business purposes:

  • To operate the Pep Promotions website and deliver the services you have requested.
  • To inform you of other products or services available from Pep Promotions and its affiliates.
  • To contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pep Promotions’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pep Promotions is among the assets transferred.

In the preceding 12 months, Pep Promotions has not disclosed and/or sold personal information to third parties for a commercial or business purpose.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of Pep Promotions’ website that are California residents to request certain information regarding Pep Promotions’ disclosure of personal information to third parties for their direct marketing purposes. To make such a request, free of charge, utilize Pep Promotions’ interactive webform at https://www.peppromotions.com/Contact-Us

Changes to this Statement

Pep Promotions updates this this Statement of Privacy at least once every twelve months in addition to occasional updates to reflect company and customer feedback. Pep Promotions encourages you to periodically review this Statement to be informed of how Pep Promotions is protecting your information.

Contact Information

Pep Promotions welcomes your comments regarding this Statement of Privacy. If you believe that Pep Promotions has not adhered to this Statement please contact Pep Promotions through our interactive webform at https://www.peppromotions.com/Contact-UsWe will use commercially reasonable efforts to promptly determine and remedy the problem.

9654897.3