Last updated: May 17, 2022
WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?
Information You Voluntarily Submit to The Website.
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Services or use certain Services.
Personal Data may include, but is not limited to, the below:
When you sign up for the Services as a Tenant and create a Platform, you will provide information to us to set up the Platform. You are the sole owner of the Content that appears on the Platform and are responsible for safeguarding it. You are also responsible for the interactions of users on the Platform and for your use of User Personal Data. You may only use User Personal Data in compliance with all relevant privacy laws. We shall not be liable for your use of User Personal Data or other information you obtain through the creation of the Platform.
When you join a platform as a User, the Tenant who invited you to join a Platform may ask you to add information about yourself. By participating in any discussions, attending events or interacting with Content, you understand that any messages you upload to the Platform will be shared with the Tenant and other users of the Platform. You are solely responsible for any information you submit through the Platform that is viewable by a tenant or other users.
Automatically Collected Information and Information We Collect from Others.
We may receive information about you from other trusted sources, such as information that validates or supplements information automatically collected. We collect information about the device you are using; tools and protocols, such as IP (Internet Protocol) addresses; device's geolocation; and other similar data for the purpose of optimization only.
Website and Platforms. When you use the Website, we may log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the Website. We may also collect usage data, which is information about actions you take when using the Website, such as links clicked.
Please see the section about third-party providers to see how this data is used and shared.
What are cookies?
A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website and through the Services. The Cookie will collect information relating to your use of our Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at our Website and Service via a link from a third party site, the URL of the linking page.
In addition to Cookies, our Website may use web beacons. Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color. A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF and tracker GIF.
What are the different types of cookies and how do we use them?
Essential - These are Cookies which are essential for the running of our Website and Services. Without these Cookies, parts of our Website and Service would not function. These Cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential Cookies include:
Functional – These Cookies are used to remember your preferences on our Website and Services and to provide enhanced, more personal features. The information collected by these Cookies is usually anonymized, so we cannot identify you personally. Functional Cookies do not track your internet usage or gather information which could be used for selling advertising.
Examples of how we may use functional Cookies include:
Analytical Performance - Analytical performance Cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users our Website and Services have. We use this information to improve user experience or identify areas of the Website and Services which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes.
Examples of how we may use analytical Cookies include:
Advertising - Behavioral advertising Cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on the web more relevant to you. Although behavioral advertising Cookies can track your activity around the internet, these Cookies cannot identify you personally.
Examples of how we may use advertising Cookies include:
Third Party Cookies - You may notice on some pages of our Website and Services that Cookies have been set that are not related to us. When you visit a page with content embedded from, for example, YouTube or Facebook, these third party service providers may set their own Cookies on your device. We do not control the use of these third party Cookies and cannot access them due to the way that Cookies work, as Cookies can only be accessed by the party who originally set them. Please check the third party website for more information about these Cookies.
How can you manage or opt-out of cookies?
Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control Cookies. In some cases, you can choose to accept Cookies from the primary site, but block them from third parties. In others, you can block Cookies from specific advertisers, or clear out all Cookies. Deleting or blocking Cookies may reduce functionality of the Website and the Services. To learn more about how to reject Cookies, visit www.allaboutcookies.org or go to the help menu within your internet browser. If you experience any problems having deleted Cookies, you should contact the supplier of your web browser.
Opting out of Analytical Performance Cookies
If you would like to opt out of Analytics Cookies, please do so by clicking on the links below:
Google Analytics: https://tools.google.com/dlpage/gaoptout
Opting out of Behavioral Advertising Cookies
If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
HOW YOUR INFORMATION MAY BE USED
We, and our subsidiaries and affiliates (the “Related Companies”), may use the information collected in the following ways:
Non-Identifiable Data: When you use the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Moon Boots may store such information itself or such information may be included in databases owned and maintained by Moon Boots affiliates, agents, or service providers. The Services may use such information and pool it with other information to track, for example, user behavior in connection with personalized ads. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, Moon Boots often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Moon Boots may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Moon Boots may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
Pseudonymized Data. Through certain of the Services, Moon Boots may collect personal data that is subsequently pseudonymized. Moon Boots has placed certain internal restrictions and security measures in place to maintain such data as pseudonymized.
Newsletters. On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behavior will not be passed on to third parties.
THIRD-PARTY USE OF PERSONAL INFORMATION
Moon Boots may share your Personal Data with certain third as set forth below:
Third Party Vendors: We may share your information with third party vendors or service providers who help us provide the Services or the Website, including database hosting and data processing services, and assist us in responding to requests by you for information that you request. Please see our list of data processors above for more specifics.
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. We may also share Personal Data with potential buyers. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Third Parties with Permission: We may share your information with third parties to whom you ask us to send your information.
Agents, Consultants, and Related Third Parties: Moon Boots, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Legal Requirements: Moon Boots may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Moon Boots, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our Customer contracts.
The Website currently uses the following third-party service providers:
Except when required by law, we will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, we may disclose or transfer personal information collected through the Website or Services to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
Personal Data Shared Within the Service.
Tenants. Tenants will have access to information about Users that subscribe to a Tenant’s Platform. Tenants will access to the User’s contact information that is provided when the User subscribes. Tenants will also have access to Personal Data about a User’s interactions with the Tenant’s Content and other user’s comments and likes. A Tenant may message with a User directly. A Tenant may also retain your personal information outside of the Service. Tenants have committed to only using your Personal Data in compliance with the law and your consent. A Tenant, or any individual that a Tenant designates as a moderator, may be permitted to delete content that you contribute to the Platform. A Tenant may upload information about users to the Platform. In doing so, the Tenant represents and warrants that the Tenant complied with all relevant laws, including privacy laws, prior to uploading the information.
RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Please contact us at email@example.com to submit a request or obtain information regarding any of the above.
Tenants. If a Tenant is using the Service to process your Personal Data, you may contact the Tenant to object, restrict, access, correct or delete your information. If you need help finding information about the Tenant, please contact us at firstname.lastname@example.org.
It is solely within your choice whether to join a Platform and how much information to share if you do. You may also request to terminate your account. To terminate your account, please INSERT DIRECTIONS.
LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)
Below are the types of lawful basis that we will rely on to process your Personal Data:
How to File a GDPR Complaint.
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
WHERE YOUR PERSONAL DATA IS HELD.
Personal Data may be held at our offices and those of our affiliates, parent or related companies, third party agencies, service providers, representatives and agents as described below (see “Third Party Use of Personal Information”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE EEA
If you are located in the EEA or the United Kingdom, we will only transfer your personal data if:
California Residents: Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have certain rights with respect to your personal information. For the purposes of this section, personal information is used as defined in the CCPA. Moon Boots reserves the right to verify all requests made pursuant to the CCPA.
Access and Disclosure
You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed. You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request.
We have not sold any personal information in the last twelve months. Please note that we are not required to:
Deletion Request Rights
You have the right to request that Moon Boots delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:
Children Under 16
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Exercising Your Rights
To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by emailing email@example.com or sending us a written request to ADDRESS.
You may only make a verifiable request for access or disclosure twice within a 12-month period. You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:
To respond to your request or provide you with personal information, Moon Boots must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at firstname.lastname@example.org. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
We will 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 by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT
We will keep your personal information while you have an account with us or we are providing
products or services to you. Thereafter, we will keep your personal information for as long as is
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; and
• To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
SENSITIVE PERSONAL INFORMATION
A privacy breach occurs when there is unauthorized access to our collection, use, disclosure or disposal of personal information. You will be notiﬁed about data breaches when Moon Boots believes you are likely to be at risk or serious harm. In the event that Moon Boots becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Moon Boots will promptly investigate and notify the applicable Supervisory Authority not later than 72 hours of having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. As a reminder, 100% of all ﬁnancial information is stored in Stripe and we as an organization do not have access to payment methods or information.
Moon Boots cannot control the actions of Tenants or Users. If you have a privacy-related dispute with a Tenant or User, you should contact the Tenant or User directly.
Links to Other Websites
If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send nonpublic personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, or as provided below; provided, however, we reserve the right to send you transactional emails such as customer service communications.
Other Terms and Conditions
Your access to and use of the Website and Services may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Moon Boots. Please refer to those agreements as needed.
Access to Information; Contacting Moon Boots:
To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Website. To unsubscribe from any communications, please contact us at the email address below.
You may contact us as follows: