Privacy Policy for Buy 360 Tour, LLC

This Privacy Policy applies to personal information collected online by Buy 360 Tour, LLC. its affiliates and subsidiaries (collectively referred to as “Buy 360”) in connection with its U.S.-based websites, microsites, mobile sites or mobile apps that expressly adopt, display or link to this Privacy Policy (collectively referred to as our “Sites”). It also applies to personal information Buy 360 collects in connection with its pages on social media sites, such as Facebook®, Twitter®, Google Plus® or others (collectively referred to as our “Social Media Pages”). Our Sites are not directed at children under the age of 13, and no one under the age of 13 should provide personal information on our Sites.

1What information does Buy 360 collect about you on our Sites and Social Media Pages?

We may collect information about you from a variety of sources, including when:

  • provide us information
  • we observe or collect information through technology
  • we receive information about you from third parties
  • we collect information on our Social Media Pages.
Information You Provide

We may ask you to provide information about yourself directly to our Sites, such as the following:

  • name
  • financial information
  • address
  • information related to customer satisfaction surveys
  • telephone number
  • government issued identifiers
  • username and password
  • personal preferences
  • birthday
  • other identifiers
  • payment card information
  • social security number
  • location information

We may allow you to use your personal social media account, on social media sites (“Personal Social Media Account”), to provide information to us when you participate in certain features on our Sites. This information may include any information you have shared on your Personal Social Media Accounts, such as the following:

  • your name
  • birthday
  • profile picture
  • education
  • gender
  • work history
  • networks
  • address
  • user ID
  • interests
  • list of friends
  • likes
  • language
  • country

It is also possible that we will be able to continue collecting this information from your Personal Social Media Accounts should the information be revised by you later. You may choose not to provide us with certain requested information, but then you might not be able to take advantage of some of the features on our Sites.

Information Observed or Collected Through Technology
aNavigational Information

Navigational information, such as the following, is collected by us and our third party service providers when you use our Sites:

  • browser type and version
  • operating system
  • the Internet service provider used to access our Sites
  • IP Address
  • use of links to arrive at our Sites
  • web pages requested and viewed
  • time spent on our Sites
  • for our mobile websites and apps, technical information about the device used, such as screen size, cookie support by the device and how images may appear
bLocation Information

Our Sites and emails include features that may require collecting different types of location information that we then use for the specific feature you have selected.

cCookies and other similar technology

We and our third party service providers use “cookies.” Cookies assign a unique identification to your device and are typically stored on your device by your web browser. We may also use pixel tags (also known as web beacons, web bugs, and clear GIFs) on the Sites and in emails. A pixel tag is a nearly invisible pixel-sized graphic image on a webpage or in an email message.

The information we and our third party service providers collect through cookies, pixel tags and similar technology includes the following:

  • your interactions with our Sites and with our advertisements
  • the time of your visit to our Sites
  • confirmation when you open email from us, including the time you open the email and whether you click on any links in the email
  • sites you visit after visiting one of our Sites.

For additional information on the use of cookies for advertising, see “3. How is technology used to serve our advertisements on other Sites that you visit and what choices do you have?”.

Information Obtained from Third parties

We may combine information about you from other sources with the information we have collected about you on our Sites or Social Media Pages.

Information Collected on Buy 360’s Social Media Pages

Personal information may be collected directly by us through our Social Media Pages. The type of information we would collect is similar to what is described above under “Information You Provide.” Personal information may also be collected by the social media site hosting our Social Media Pages. Our Privacy Policy does not cover the privacy and security practices of the social media sites on which Buy 360 has its Social Media Pages.

2How do we use the information we collect about you?

The information we learn from you helps us personalize your experience with us and our communications to you, and helps us continually improve your experience on our Sites.

We use the information you provide, information collected through your Personal Social Media Accounts, and information collected on our Social Media Pages for things like:

  • opening an online account
  • responding to your inquiries
  • improving and developing our service
  • market research and surveys
  • servicing our customers
  • conducting events, promotions, contests and sweepstakes
  • advertising and marketing, including emails and postal mail
  • analytics
  • personalizing your experience when visiting our Sites
  • processing payments

We use navigational information gathered through technology for determining things like:

  • which parts of our Sites are most visited or used
  • difficulties visitors may experience in accessing our Sites
  • what features/products are browsed
  • monitoring the number of visitors to our Sites
  • how to improve and better transact business
  • average time spent on our Sites
  • the effectiveness of our Sites
  • any programming errors or failures on any of our Sites
  • lead generation

We use information collected through cookies and similar technology to determine many of the same things listed for navigational information above. In addition cookies and similar technology are used for things like:

  • personalizing your experience on our Sites
  • serving tailored ads on other sites, as described below
  • tailoring email marketing to you based on your preferences on or use of our Sites
  • determining return visitors
  • measuring the effectiveness of our advertising.

We use third-party analytics providers, such as Google Analytics, to measure traffic and usage trends, and to help us better understand your use of and interaction with our Sites and Social Media Pages. For more information on how Google uses data when you use our Sites, click here.

Similar to the navigational information described above, the social media sites where we have our Social Media Pages may provide aggregate information and analysis to us about visitors to our Social Media Pages. This allows us to better understand and analyze our user growth, general demographic information about the users of, and interaction with content on, our Social Media Pages.

3How is technology used to serve our advertisements on other sites that you visit and what choices do you have?

We may contract with third party advertising companies to tailor online advertising to be directed to you on other websites. These third party advertising companies place, use, or rely on technology, such as cookies and pixel tags, to obtain information about your interactions with our Sites as well as with other websites. This information helps us select advertising to serve to you and where to serve it based on your experience on our Sites and other sites that you visit.

For information about opt out programs that these third party advertising companies participate in, and the effect of opting out, click the following: DAA Opt Out click here or NAI Opt Out click here. By clicking these links, you will then leave our Site for another online site where you may specify your preferences under that opt-out program. You can also click the preference icon that may appear on some of our advertising served through these technologies. You should also note that our systems may not recognize “Do Not Track” headers from some or all browsers.

4Does Buy 360 share your information with third parties?

We do not sell, rent, or trade your personal information to unrelated third parties except as set forth below. We may share your personal information with the following:

  • our contractors, vendors and affiliates so that they can provide information to you about their products and services,
  • our contractors, vendors, affiliates and service providers in order to perform tasks on our behalf such as the following:
    • facilitating your payments
    • assisting us in providing our services
    • providing and improving our communications with you
    • responding to requests
    • cloud based and hosting services
  • when it is necessary for completing or servicing any transactions that you have authorized and, in some instances, to verify the existence or condition of your account with a financial institution, credit bureau or other third party
  • as required to cooperate with a subpoena, search warrant or other legally valid inquiry, court order or other legal process, or as required or permitted by law
  • to protect the rights, property or safety of our Sites, our users or others, including where necessary for the establishment, exercise or defense of legal claims
  • as necessary and appropriate to protect Buy 360 from harm due to fraud or other illegal activities.

If Buy 360 were ever merged with or acquired by another company, or if we acquire another business entity or are involved in a corporate reorganization or other change of control, or if we sell substantially all the assets of a division, affiliate or subsidiary, some or all of the personal information collected about you could be shared with the acquiring or acquired company.

We may also share aggregate data about our sales, customers, traffic patterns, and other related Site information with third parties, but none of this data is connected to an individual’s personal information.

5What choices do you have over how Buy 360 uses your information?

1. Email:

You may opt-out of our marketing emails by following the instructions listed in the email that you received. However, even if you opt-out you may still receive non-marketing emails, such as customer service communications.

2. Location Information:
aMobile Device Location Information

Your mobile device settings may allow you to disable location-based services, which will prevent our Sites from accessing your precise mobile device location information. We recommend you review the help or user manual provided with your device for instructions.

bDesktop Device Location Information

Your desktop web browser may allow you to remove permission you granted through your desktop device for our Sites to access your location information and/or completely block requests for location information. We recommend you review the help or user manual provided with your browser for instructions.

cEmail Location Information

Your email program may allow you to prevent the pixel tags or images in the emails you receive from us from downloading, which will also prevent our service provider from accessing your location information. You can also unsubscribe from receiving our emails, as described in the "Email" section above.

3. Postal Marketing:

If you no longer want to receive marketing materials from us via regular postal mail, please notify us using our contact us page or call us at (330) 688-0120, and tell us that you want to be removed from Buy 360’s postal mailing list, including the postal address you wish to have removed.

4. California Opt-Out Rights:

Under California law, if you are a resident of California and have previously communicated with us or provided us with your personal information, you may make a request to us about how we have shared your personal information during the prior calendar year with others for their direct marketing purposes. In response to your request, we are allowed to provide you with a cost-free means to opt-out of such sharing rather than provide the information about those parties. We are providing you the opportunity to opt out, which you can do by submitting an opt out request to our contact us page that includes your name and all of the addresses and other contact information that you have provided to use.

Additionally, California residents have the right to request that we disclose the categories of personal information collected; the categories of sources from which personal information is collected; the business or commercial purpose; the categories of third parties which the businesses shares personal information and the specific pieces of information we hold about you. The vast majority of this information is contained within this Privacy Policy, but you can make further access requests by submit a request at our contact us page, writing us at the address below, or calling us at (330) 688-0120. Similarly, California residents can choose to direct us to delete certain pieces of their personal information, which you can do using any of those same methods (contact us page, letter, phone). While California law also allows for California residents to opt out of the sale of their personal information, All Buy 360 does not “sell” personal information. For further details on California residents’ privacy rights see Cal Civil Codes §§ 1798.80-83.

6How does Buy 360 store and secure your information on its Sites?

Our employees involved in data processing and our servers are based in the state of Ohio, and other locations throughout the U.S. We work with affiliated and unaffiliated service providers in the U.S., the U.K., and other jurisdictions around the world.

Our Sites utilize encryption technology. We also use firewalls and have implemented other reasonable technical, administrative and physical measures designed to protect the personal information in our custody or control from unauthorized access, use, modification and disclosure. While we implement these security measures on our Sites, you should be aware that 100% security is not always possible.

7Will this Privacy Policy change?

We may make changes to this Privacy Policy at any time, so please review it periodically. We will update the effective date of the Privacy Policy at the time a change is made.

8How can I contact Buy 360?

If you have questions or concerns with respect to our Privacy Policy, please contact us by calling us at (330) 688-0120, submitting an inquiry to our contact us page, or writing us at the following address: 3589 Darrow Road, Stow, Ohio, 44224 Attn: Privacy Policy, making sure to include your question, name and contact information.

9Supplemental Privacy & Cookie Notice for Visitors from the European Economic Area

If you are accessing our Sites from a member state of the European Economic Area ("EEA"), this Supplemental Privacy Notice applies to you in addition to our Privacy Policy. This Supplemental Privacy Notice does not otherwise apply to visitors who are accessing our Services from outside the EEA.

European Union Regulation 2016/679 of 27 April 2016, governing the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("EU GDPR"), requires us to provide additional and different information about our data processing practices to data subjects in the EEA

Cookies

We use the following web cookies and other information technologies to provide features on our web and mobile sites to users in the EEA, including cookies that deliver basic visitor experiences, fuller website experiences such as interactivity with third-party content, and our interest-based advertising on other websites.

The following types of cookies (and cookie technology) are enabled when a web or mobile user visits our Sites:

Cookies (and cookie technology) and their functions

Cookie / Technology Type Function
User-Input Cookies Enables visitors’ input, choices, or selections across their website experience.
Authentication Cookies Identifies visitors through the Sites after they log in.
Security Cookies Helps to ensure our Sites’ security when visitors request a service. For example, we use cookies to help secure account creation and login pages.
Multimedia Player Cookies Ensures such things as image quality, network link speed, or buffer information for video and audio playback.
Visitor Customization Cookies Stores preferences and visitor experiential histories: remembers language preference, product-page display preference, and whether certain visitor experiences should be displayed, such as email marketing signup, based on past experiences.
Social Media Plug-in Cookies These cookies from social media platforms (like Facebook and Instagram) facilitate content sharing on those platforms.
Interest Based Advertising Cookies Enables our advertising vendors to deliver tailored ads to our visitors on other websites. The ads are based on a visitor’s experience with us, as well with our vendors’ network of advertisers.
Analytics Cookies Enables us to do things like estimate number of visitors, detect most used search-engine keywords that lead to a webpage, measure page load times, administer visitor surveys, identify navigation issues, and improve web capabilities.

We, the data controller, are Buy 360 Tour, LLC, 3589 Darrow Road, Stow, Ohio, 44224. We have designated a Data Protection Officer who has the duty to: Ensure by contract that third parties to whom the company transfers personal information will adequately protect the information and use it only for specified lawful purposes, protect Your personal data using appropriate security measures, notify authorities of personal data breaches, obtain appropriate consents for processing data, ensure proper response to Your GDPR requests, keep records detailing data processing, train privacy personnel and employees, and to audit and update Our Privacy Policies. If You have any questions about Your Privacy Rights under the GDPR and Our Privacy Policy please feel free to contact Our Data Protection Officer by submitting a request using our contact us page.

The legal basis for our processing of your personal data in connection with our Services is Art. 6.1(b) EU GDPR, which allows processing of personal data as necessary for the performance of a contract. When you access our Services, you form a contract with us based on our Terms of Use, Conditions and Notices, and we need to process your personal data to respond to your requests, facilitate our services, and satisfy our obligations with respect to the other purposes listed in our Privacy Policy.

As exceptions, we rely on your consent with respect to cookies and direct marketing emails per Art. 6.1(a) EU GDPR, and legitimate interests under Art. 6.1(f) EU GDPR, especially with respect to situations where we must process your personal data to comply with applicable laws (as a U.S.-based company, we are subject to U.S. laws and must comply, just like EEAbased companies have to comply with EEA laws).

Recipients or categories of recipients of your personal data are employees of our company and affiliated and non-affiliated services providers who have a need to know.

When you access our Sites, you transfer your personal data to the United States of America for which the European Union Commission has not yet issued an unlimited adequacy decision.

We will process and keep your personal information for as long as is necessary for the purposes set out in this Privacy Policy, for our legitimate business needs, and for compliance with the law.

You have a right to request from us these EU GDPR rights concerning your personal data: access to data; rectification of data; erasure of data; restriction on processing; objection to data processing; and data portability. You can exercise these rights through a combination of actions: accessing the information in your account; exercising your opt-out options through our Services; and by calling or emailing as set forth in Section 8 of this Privacy Policy.

If you have provided consent for direct marketing emails or other data processing, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

We do not use automated decision-making, including profiling, as referred to in Article 22(1) EU GDPR, that is, in a way that produces legal effects concerning you or significantly affects you. Our Services' customization technologies and e-commerce processes are automated, but do not produce legal effects or affect you significantly as contemplated by Art. 22(1) or (2) EU GDPR.

Effective as of: September 13, 2019