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Privacy Policy

Last Updated on January 9th, 2020 to add information about our compliance with the California Consumer Privacy Act (CCPA). Read the section Privacy Policy for California Residents to see the update.

 

MSA Reviews LLC (“us”, “we”, or “our”) operates the https://www.mysubscriptionaddiction.com website and subdomains (swaps.mysubscriptionaddiction.com and boxes.mysubscriptionaddiction.com) (the “Service”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.mysubscriptionaddiction.com

Definitions

  • Service
    Service is the https://www.mysubscriptionaddiction.com website and subdomains (swaps.mysubscriptionaddiction.com and boxes.mysubscriptionaddiction.com) operated by MSA Reviews LLC
  • Personal Data
    Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data
    Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Cookies
    Cookies are small pieces of data stored on your device (computer or mobile device).
  • Data Controller
    Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
    For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
  • Data Processors (or Service Providers)
    Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
    We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User)
    Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, by managing your notification settings in your account, or by contacting us.

Usage Data

We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

MSA Reviews LLC uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), MSA Reviews LLC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

MSA Reviews LLC may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • To comply with the law

Retention of Data

MSA Reviews LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

MSA Reviews LLC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

MSA Reviews LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure Of Data

Business Transaction

If MSA Reviews LLC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, MSA Reviews LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

MSA Reviews LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of MSA Reviews LLC
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. MSA Reviews LLC aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your personal information.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where MSA Reviews LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics
    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

  • Google AdSense & DoubleClick Cookie
    Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
    You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

Privacy Policy for California Residents

This Privacy Policy for California Residents section supplements the information above and applies solely to consumers who reside in the State of California (“consumers” or “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Information We Collect

We collect 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, household, or device (“personal information”). Personal information does not include publicly available information from government records or deidentified or aggregated consumer information.

We may have collected the following categories of personal information from our users in the last twelve (12) months:

 

Category Collected? Data Collected, If Applicable
Identifiers Yes Name, alias, postal address, IP address, email address.
Customer Records Information No Not applicable
Characteristics of protected classifications under California or federal law Yes Race, religion, sexual orientation, gender identity, gender expression, age.
Commercial Information Yes Records of subscription boxes purchased (a user’s “Have List”) or considered (a user’s “Wish List”), records of products listed on swap site.
Biometric information No Not applicable
Internet or other electronic network activity information Yes Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation data Yes IP address
Audio, electronic, visual, thermal, olfactory, or similar information No Not applicable
Professional or employment related information No Not applicable
Education information No Not applicable
Inferences drawn from other personal information No Not applicable

Sources of Personal Information

A majority of the information we collect is submitted directly by users of our website or otherwise collected on our website. We do collect personal information from other sources in some cases:

  • If you link your Facebook account for login purposes, you will share certain personal information with us, for example your name, email address, photo, and the names of your friends who also use and have shared their friends lists with My Subscription Addiction. The specific information transferred depends on your privacy settings within Facebook.
  • If you enter giveaways or complete on our site using third party tools such as SurveyGizmo or ViralSweep, we receive your e-mail address and name for the purposes of contacting participants about prizes or follow-up questions. Optionally, users who submit these forms can join our mailing list if they choose to do so.

Sales of Personal Information

In the preceding twelve (12) months, My Subscription Addiction has not sold any personal information for commercial purpose or valuable consideration.

Use of Personal Information & Sharing With Third Parties

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To allow you to participate in interactive features of our Service when you choose to do so (for example: comments, user reviews, swaps, wishlists, giveaways, product sampling)
  • To provide you with a personalized website experience according to your preferences
  • To provide you with news, special offers and general information about other goods, services and events that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information
  • To provide, support, develop, and maintain our Service
  • To notify you about changes to our Service
  • To provide you with support and respond to your inquiries
  • For testing, research, analysis and product development, including to develop and improve our website, products, and services
  • To monitor the usage of our website and to detect, prevent and address technical issues
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We work with trusted third parties to perform functions and provide services to us, including but not limited to hosting and maintenance of our website, analytics and monitoring, e-mail marketing, giveaways, product sampling, and user surveys. We may disclose your Personal Information to a third party in order to perform these functions and provide these services. We require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.

Users who choose to leave comments or provide written reviews on our website should understand that the text of those comments along with their username or alias (as entered by the user) and URL (if provided) is made publicly available online. E-mail address and IP address are not publicly available and are used for moderation purposes only, but we may contact you via the e-mail you’ve provided in direct response to submitted comments or reviews.

 

Category Disclosed for Business Purposes? Purpose(s), if applicable
Identifiers Yes Security, debugging, performing services, internal research, testing or improvement of our website,  short term uses.
Customer Records Information No Not applicable
Characteristics of protected classifications under California or federal law No Not applicable
Commercial Information Yes Performing services, internal research, short term uses.
Biometric information No Not applicable
Internet or other electronic network activity information Yes Internal research, testing or improvement of our website.
Geolocation data Yes Internal research, testing or improvement of our website.
Audio, electronic, visual, thermal, olfactory, or similar information No Not applicable
Professional or employment related information No Not applicable
Education information No Not applicable
Inferences drawn from other personal information No Not applicable

Your Rights and Choices Under CCPA

  • Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the last 12 months. Once we receive and confirm your request, we will disclose to you:
    • The categories of personal information we collected about you.
    • The categories of sources for the personal information we collected about you.
    • Our business or commercial purpose for collecting or sharing that information.
    • The categories of third parties with whom we share that personal information.
    • The specific pieces of personal information we collected about you (also called a data portability request).
    • If we shared or disclosed your personal information for a business purpose, two separate lists disclosing:
      • the sharing, 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.
  • Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
    • We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
      • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
      • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
      • Debug products to identify and repair errors that impair existing intended functionality.
      • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
      • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
      • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
      • 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.
  • Right to Non-Discrimination. You have the right not to be discriminated against for having exercised your rights under the CCPA. Unless permitted by the CCPA, we will not:
    • Deny you goods or services
    • Charge you different prices or rates for goods or servies, including through granting discounts or other benefits, or imposing penalties
    • Provide you a different level or quality of goods or services
    • Suggest that you may receive a different price or rate of goods or services of a different level or quality of goods or services

Exercising Your Rights Under CCPA

To exercise your rights to access, data portability, and deletion as described above, please submit a request by:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response electronically via e-mail.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy or need to issue a right of access or deletion request, please contact us:

Written by MSA

MSA

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