Privacy

CommentSold Privacy Policy

We, CommentSold, Inc. (the “Company” or “We”) respect your (the “User” or “You” or “Your” or “Yourself”) privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information, including Personal Data, We may collect from You or that You may provide when You visit our website or use of our software services, applications and e-commerce platform services (the “Sites” or “Services) or our third party partner’s sites or services. By accessing the Services, and/or setting up an account or providing your information, You are hereby agreeing to the CommentSold Privacy Policy (“Privacy Policy”), in addition to any applicable terms and conditions of the Service.  The Privacy Policy addresses the Company’s practices for Processing, collecting, using, sharing, maintaining, protecting, and disclosing any information collected by the Company in Your use of the Services.  This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Services.  

DEFINITIONS

Account means a CommentSold account or, as applicable, Your use of the Services, since the use of our Services does not always require an Account.

Device Information  means data that can be automatically collected from any device used to access the Sites or Services.  Such information may include, but is not limited to, your device type; your device ID; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Sites or Services; Location Information; information about apps downloaded to your device. 

Location Information means information that identifies with reasonable specificity your location, for example your county or neighborhood.  We do not determine your location through longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation, but may obtain other Location Information, either directly or via our third party partners like Google and Facebook, that would be able to further identify you when paired with other Personal Data we may obtain.

Personal Data means personal information that can be associated with an identified or identifiable person.  “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number (partial or full), other financial account information, account number, date of birth.  In certain instances we may have access to other Personal Data from our third-party partners, such as government-issued credentials (e.g., driver’s license number, national ID, Social Security number and Taxpayer ID), where you have agreed to allow us to access that Personal Data under the privacy policy applicable to such third-party partner’s service (e.g., Stripe).   Personal Data does not include information that does not identify a specific User. 

Process or Processing  means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services.  Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies. 

WHAT PERSONAL DATA DO WE COLLECT?

 

We may collect information about you when you visit our Sites or use our Services, including the following:

  • Registration and use information – When you register for or use our Services, or otherwise provide information to us, we will collect Personal Data as necessary to offer and fulfill the Services you request.  Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, payment information, email address and identification information to establish an Account or use the Services.  We may also require you to provide us with additional Personal Data as you use our Services.
  • Transaction and experience information – When you use our Services or access our Sites, we collect information about your transactions, as well as other information associated with the transaction, which may include payment information (e.g. last four digits of your credit card number and expiration date), Device Information, Location Information and Technical Usage Data.
  • Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you if you provide it to us.
  • Information about you from third-party sources – We obtain and Process Personal Data from third-party partners and service providers in connection with your use of our Service, including merchants, payment processors, partners and data and service providers.  For example, we may collect certain Personal Data such as name, email address and Location Information when you authenticate through a third-party site like Google or Facebook, as well as certain account information when you use our third party payment processors, e.g. Stripe.
  • Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey. 

WHEN DO WE RETAIN PERSONAL DATA

 

We retain Personal Data for our business purposes, to provide the Services and to fulfill our legal or regulatory obligations.  We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.  If your Account is closed, or you ask us to delete your information, we may take steps to mask Personal Data and other information in accordance with law.  We reserve at all times our ability to retain and access Personal Data for so long as required to comply with applicable laws, and in such cases, we will continue to use and disclose such Personal Data in accordance with this Privacy Policy and law.

 

HOW DO WE PROCESS PERSONAL DATA?

 

We may Process your information for the following reasons:

  • To operate the Sites and provide the Services, including to:
  • authenticate your access to an Account;
  • communicate with you about your Account, the Sites or the Services;
  • create an account communication between your Account and a third-party account or platform;
  • initiate a transaction, purchase and/or payment;
  • evaluate applications, and compare information for accuracy and verification purposes; and
  • keep your account and payment information up to date.

  • To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behavior and perform research about the way you use our Services.

  • To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. We may use Personal Data, Device Information, Technical Usage Data and Location Information from our Sites and websites to help detect and prevent fraud and abuse of the Services.

  • To market to you about our products and Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to tailor the marketing content and certain Services or Site experiences to better match our understanding of your interests on our Sites and other third-party websites.
  • To advertise to you on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature, or offer to you on third-party websites.  We may use cookies and other tracking technologies like pixels to help advertise to you and/or work with other third-parties such as merchants, advertising or analytics companies to be able to serve ads to you on third-party websites or platforms. We do not sell your Personal Data for these purposes or via these means, but rather use it to be able to identify you and serve you relevant advertisements for our Services.
  • To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.

  • To respond to your requests, for example to contact you about a question you submitted to our customer service team.

 

DO WE SHARE PERSONAL DATA?
 

We may share your Personal Data or other information about you with others as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons:

 

With merchants with whom you transact on our Service: We may share Personal Data and payment information with the merchants with whom you transact on our Service.

 

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf.  These third-party service providers may, for example, provide you with Services, assist in processing transactions, allow us to send you advertisements for our products and Services, provide customer support, send email marketing on our behalf, etc. We do not sell your information to these third-party service providers.

 

In aggregated, anonymous form to provide data to third parties for our benefit: We may provide aggregated statistical data to third-parties for our own analytics and business purposes.  This data will not personally identify you or provide information about your specific use of the Sites or Services.  We do not share your Personal Data with third parties for their marketing purposes without your consent.

With the other parties to transactions when you use the Services, such as payment processors and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes payment processors and their service providers. The information might include:

  • Personal Data, payment information and Account information necessary to facilitate and/or authenticate the transaction;
  • information to help resolve disputes and detect and prevent fraud; and
  • aggregated data and performance analytics to help us and our merchants better understand user behavior and to help us enhance user experiences. 

With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including:

  • if we need to do so to comply with a law, legal process or regulations;
  • to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to Us;
  • if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  • to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
  • to protect our property, Services and legal rights;
  • in connection with shipping, payment and related services for purchases made using a Service;
  • to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;
  • to banking partners/payment processors as required by card association rules;
  • to credit reporting and collection agencies;
  • to companies that we plan to merge with or be acquired by; and
  • to support our audit, compliance, and corporate governance functions.

With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account communication with a third-party account or platform. 

 

HOW DO WE WORK WITH OTHER SERVICES?

 

A significant benefit and innovation of our Services is the ability to interact and transact with third-party merchants, payment providers and platforms.  For the purposes of this Privacy Policy, an “account communication” with such a third-party is an interaction (communication) between the Services and a non-CommentSold account, merchant, payment instrument, or platform.  As set forth throughout this Privacy Policy, We and certain third-party may exchange your Personal Data and other information directly for various purpose related to our Services and as otherwise described in this Privacy Policy.  

 

As set forth throughout this Privacy Policy, we may receive information from the third-party about you and your use of the third-party’s service.  For example, we may have access to your purchases, account balance and transactional information.  We will use all such information that we receive from a third-party via an account communication in a manner consistent with this Privacy Policy.  Information that we share with a third-party based on an account communication will be used and disclosed in accordance with the third-party’s privacy practices.

 

HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES LIKE PIXELS

 

When you visit our Sites or use our Services, we and our business partners and vendors may use cookies and other tracking technologies like pixels (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, serve you online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services.  Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties.  We do not respond to DNT signals.

 

HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration.  The security measures include firewalls, data encryption, access controls to our data centers, and information access authorization controls.  While we are dedicated to securing our systems and Services, you are not responsible for securing and maintaining the privacy of your password(s) and Account/profile information and verifying that the Personal Data we maintain about you is accurate and current.  We are not responsible for protecting any Personal Data that we share with a third-party based on an account communication that you have authorized.

 

CAN CHILDREN USE OUR SERVICES? 

 

The Sites and Services are not directed to children under the age of 13.  We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us immediately if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.

 

CHANGES TO THIS PRIVACY POLICY

 

We may revise this Privacy Policy from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Policy will be effective as of the published effective date. 

 

CONTACT US

 

You may contact us if you have general questions about our Privacy Policy and practices or questions about your Account/profile information or Personal Data. 

We want to make sure your questions go to the right place:

 

  • Click here to contact us
  • California residents click here to contact us


CALIFORNIA CONSUMER PRIVACY ACT NOTICE

 

This notice should be read together with our Privacy Policy and applies to all California residents who visit our Sites or use the Services.

 

Under the California Consumer Privacy Act (“CCPA”), California consumers have the following rights, which can be exercised directly or in certain cases, through an authorized agent:

 

Right to Know. You have the right to request information about the categories and sources of personal information (Personal Data) we collect, our purposes for collecting the information, and the types of third parties that receive that information. In addition, you have the right to request a copy of your personal information. You may exercise this right once per 12-month period by clicking here or calling us at 1 (855) 593-0401‬ Toll Free.

 

Right to Delete. You have the right to request that we delete some or all of the personal information (Personal Data) that we have about you. Deleting all data will typically require the deletion of your account, along with all content. Notwithstanding the foregoing, we may retain information to provide services you have ordered, complete transactions, honor opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, and to exercise and defend our rights. You may contact us by clicking here or calling us at 1 (855) 593-0401‬ Toll Free.

 

Do Not Sell. You have the right to opt out of the sale of your personal information (Personal Data), and to request information about whether we have sold your personal information in the past 12 months. We do not sell personal information, and we have not done so in the past 12 months. If we begin to do so, we will update this notice prior to doing so and provide a mechanism to opt out of any such sale.  

 

Non-Discrimination. We won’t discriminate against you because you exercise any rights herein.

To exercise your rights to know and delete, we must be able to verify your identity as the owner of the information you are inquiring about. We may not be able to fulfill your request until we can do so. In general, we verify identity by confirming that you are the owner of the email address associated with the account. An authorized agent submitting a request on your behalf must also have access to the email address associated with the account, along with sufficient evidence that you have authorized that person to submit the request on your behalf. Although you need not have an account to submit a request, we may not be able to locate certain information to process your request if you don’t have one.

 

Personal Data Collection and Purposes of Use

We collect, use and share personal data regarding California residents as described in this notice.

 

We did not sell any consumers' personal data in the preceding 12 months.

California Residents' Privacy Rights

 

In the preceding 12 months, we have collected the following categories of personal data from California residents:

We have collected such personal data from the following categories of sources:

We collected such personal data to use for the following purposes:

In the preceding 12 months, we shared personal data with the following categories of third parties:

a. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

  • from you when you use our Site and Services
  • merchants
  • payment processors
  • partners
  • service providers

 

  • operate the Sites and provide Services
  • initiate a payment or transaction
  • authenticate your access to our Services
  • communicate with you about the Sites and the Services
  • create an account communication between Our Services and a third-party merchant, account or platform 
  • for accuracy and verification purposes
  • keep your Account and information up to date
  • manage our business needs, such as monitoring, analyzing, and improving the Services and Sites’ performance and functionality
  • market to you about the Services and the products and services of unaffiliated businesses
  • comply with our obligations and to enforce the terms of our Sites and Services
  • respond to your requests

 

  • parties to transactions when you use the Services, such merchants, payment processors, and their service providers
  • third parties for our business purposes or as permitted or required by law
  • third-party service providers for analytics and advertising purposes

 

 

 

 

 

 

b. Personal data listed in California Customer Records statute, which may include: name, signature, address, telephone number, credit card number, debit card number, or other financial information.

  • from you when you use our Site and Services
  • merchants
  • payment processors
  • partners
  • service providers

 

 

 

  •  operate the Sites and provide Services
  • initiate a payment or transaction 
  • authenticate your access to our Services
  • communicate with you about the Sites and the Services
  • create an account communication between Our Services and a third-party merchant, account or platform 
  • for accuracy and verification purposes
  • keep your Account and information up to date
  • manage our business needs, such as monitoring, analyzing, and improving the Services and Sites’ performance and functionality
  • market to you about the Services and the products and services of unaffiliated businesses
  • comply with our obligations and to enforce the terms of our Sites and Services
  • respond to your requests

 

  • parties to transactions when you use the Services, such merchants, payment processors, and their service providers
  • third parties for our business purposes or as permitted or required by law
  • third-party service providers for analytics and advertising purposes

 

 

c. Personal data that is protected under California or federal law.

  • from you when you use our Site and Services
  • merchants
  • payment processors
  • partners
  • service providers

 

  •  operate the Sites and provide Services
  • initiate a payment or transaction
  • authenticate your access to our Services
  • communicate with you about the Sites and the Services
  • create an account communication between Our Services and a third-party merchant, account or platform
  • information 
  • for accuracy and verification purposes
  • keep your Account and information up to date
  • manage our business needs, such as monitoring, analyzing, and improving the Services and Sites’ performance and functionality
  • market to you about the Services and the products and services of unaffiliated businesses
  • comply with our obligations and to enforce the terms of our Sites and Services
  • respond to your requests

 

  • parties to transactions when you use the Services, such merchants, payment processors, and their service providers
  • third parties for our business purposes or as permitted or required by law
  • third-party service providers for analytics and advertising purposes

 

d. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.

  • from you when you use our Site and Services
  • merchants
  • payment processors
  • partners
  • service providers

 

  • operate the Sites and provide Services
  • create an account communication between Our Services and a third-party merchant, account or platform 
  • for accuracy and verification purposes
  • manage our business needs, such as monitoring, analyzing, and improving the Services and Sites’ performance and functionality
  • market to you about the Services and the products and services of unaffiliated businesses
  • comply with our obligations and to enforce the terms of our Sites and Services
  • respond to your requests

 

  • parties to transactions when you use the Services, such merchants, payment processors, and their service providers
  • third parties for our business purposes or as permitted or required by law
  • third-party service providers for analytics and advertising purposes

 

e. Location data.

 

  • from you if you provide this information to us
  • from you when you use our Site and Services
  • from merchants on our Service
  • from our service providers

 

 

 

  • provide the Services
  • manage our business needs, such as monitoring, analyzing, and improving the Services and Sites’ performance and functionality
  • provide you with location-specific options, functionality or offers
  • market to you about the Services
  • manage risk and protect the Sites and Services
  • comply with our obligations and to enforce the terms of our Sites and Services

 

  • parties to transactions when you use the Services, such merchants, payment processors, and their service providers
  • third parties for our business purposes or as permitted or required by law
  • third-party service providers for analytics and advertising purposes