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Privacy Policy

Section I: Introduction and Definitions
This Privacy Policy governs all websites, apps, publications and other Services that link to, or contain references to, this document and are published or made available by SEPI, LLC its parent, subsidiaries and affiliates (“we”, “us” or “our”). Please read this Privacy Policy carefully. It summarizes the various ways we acquire and treat your Data when you access, visit and/or use the Service. It also governs your Data that we may acquire offline. This Privacy Policy does not cover information collected on sites, applications, destinations, or services linked to from the Service that we do not own or control.

You can access this Privacy Policy any time in the footer of the Service’s home page, via the menu button or on the Service description screen, or as otherwise indicated depending on the Service you are using. By purchasing a Service, registering for any aspect of the Service, or otherwise accessing, visiting or using the Service, you consent to this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, you should not access, visit and/or use the Service. We advise that you print or retain a digital copy a copy of this Privacy Policy for future reference.

In addition to reviewing this Privacy Policy, please also review our User Agreement and any other terms and conditions that may be posted elsewhere in the Service or otherwise communicated to our users, because the User Agreement and all such terms and conditions are also part of the Agreement between you and us.

All capitalized terms used in this Privacy Policy that are not otherwise defined have the meanings set forth in the Glossary. “Personally Identifiable Information” that alone or in combination with other information or in certain contexts can be used to identify, distinguish or trace you or your Device(s) is referred to in this document as “PII”. PII, together with all other information about you and/or your Device(s) that we acquire is referred to collectively as your “Data”.

This Privacy Policy may be modified from time to time, so check back often. So that you are aware changes have been made, we will adjust the “Last Revised” date at the beginning of this document. If we make a significant change in the way we use or share your PII, we will also post on the Service a prominent notice that a change was made. Continued access of the Service by you will constitute your acceptance of any changes or revisions to the Privacy Policy.

Section 2: The Types of Data Acquired About You
Personally Identifiable Information (PII). We acquire PII that may include, in certain contexts, your name, postal address, zip code, email address, and telephone number. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII because it could be used to identify an individual or Device if it were combined with other identifying information.
Sensitive PII. In certain circumstances, such as when purchasing a Experience, you may provide a credit, debit, or payment account number, or other payment information which we recognize as more sensitive than other PII. We generally do not request on or through the Service other Data that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personal health information, or government issued identification numbers (e.g., social security number, drivers’ license number, or passport number), although we reserve the right to do so when such Data is necessary to offer you certain services.
Anonymous Data. Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.

Section 3: How We Acquire Your Data
Data You Provide. We mostly receive PII because you provide it to us. For instance, when you enter a contest, complete a survey, purchase a Experience, or register and/or set up an account/profile, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Data such as your age, gender, an avatar, and preferences may also be requested. In addition, we may acquire your Data when you contact us by telephone, postal mail, social media interaction or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire information that you provide about other people, for example, when you use our “refer-a-friend” email feature or purchase one of our Experiences as a gift.

Data Automatically Collected. The Service may also automatically collect Data about you, your online behavior and your Device. The Data collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The Service may collect your Data even if the Service is not open on your Device or you’re not logged in.
Data Acquired Elsewhere. We may also acquire your PII or other Data offline or otherwise outside of the Service. For example, we may purchase or otherwise acquire such Data from third party data suppliers. We reserve the right to merge or co-mingle this other Data with your PII and Data collected on or through the Service.

Social Network Integration. If you choose to access, visit and/or use any third party social networking service(s) that may be integrated with the Service, we may receive your Data that has been made available to those services, including information about your contacts on those services. For example, some social networking services allow you to push Content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. Your decision to use a social networking service in connection with our Service is voluntary. However, you should make sure you are comfortable with your Data the third party social networking services may make available us by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We reserve the right to use, transfer, assign, sell, share, and provide access to all of your Data that we receive through third-party social networking services in the same ways as all of your Data we receive through our Service (as described in Section IV below).

Be Careful Publicly Posting PII. Please be aware that Content and PII that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all PII, especially sensitive PII, that you may wish to post.

Section 4: How We Use Your Data
Processing Your Requests for Services. We use your Data to process your request for Content and/or other Experience(s). For example, if you order any of our Services we may use your e-mail address to send you a confirmation notice and your mailing address to send you any additional information. Similarly, if you enter a contest, we will use your PII to notify you if you are a winner. If you enter a contest or submit Content to us (e.g., a “letter to our editors” or online review or comment), we may also publish your name, screen name, home town and other PII you have provided to us.

Administering the Service. We also use your Data for any lawful business purpose in connection with administering the Service, including without limitation for customer service, to help diagnose problems with servers, to improve Services that we offer by tailoring them to your needs, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users’ movements around the Service and elsewhere on the web or across apps and/ devices. Your geographic location Data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location.

Access by Third Party Providers. We may also allow access to your Data by Third Party Providers that provide us with services, such as technical maintenance, market research, community and forums management, auction services, e-commerce, personal/job search and other advertising functionality, but only for the purpose of and to the extent necessary to provide those services. And if you choose to purchase or subscribe to any Experience(s), we may forward your Data to Third Party Providers for services such as credit/debit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. There are also times when you provide Data to us in areas of the Service that may be managed or participated in by one or more Third Party Providers. In such cases, the Data may be used by us and by such Third Party Provider(s), each pursuant to its own policies. While we may seek to require Third Party Providers to follow appropriate privacy policies and will not authorize them to use your Data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.

Marketing Communications. We may also use your Data to communicate with you about new features, events or Experiences offered by us, Third Party Providers, our advertisers, and other companies and individuals with which we have a relationship.

Health, Safety, and Legal Requests. We reserve the right to access, use, and share with others your Data for purposes of health, safety and other matters in the public interest. We may also provide access to your Data in order to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also provide access to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.

Employment Opportunities. If you provide your PII to us in connection with an employment inquiry, without limiting the applicability of the rest of this Privacy Policy, we will use your PII to evaluate your job application, and for related recruiting, reporting and recordkeeping purposes. We may maintain your PII on file, whether we hire you or not, to administer your relationship with us and/or for job applicant related reporting and recordkeeping for as long as required or permitted by law.

Transfer or Sale of Our Business. As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Data may be among the transferred assets.
Combining Your Anonymous Data with PII. We reserve the right to merge or co-mingle anonymous, non-personally identifiable Data about you, your offline and online behavior, and/or your Device (including its geographic location), with your PII for any lawful business purpose.

Section 5. Sharing Your Data for Marketing; Opt-Out; How to Update Your Data
Credit/Debit Card and Payment Account Data. We will not sell or rent your credit/debit card number or payment account Data. We may transfer such Data to Third Party Providers who need access to fulfill a transaction.

Sharing Your Data for Marketing. Unless otherwise specified on the Service, we may sell or share your Data among our parent, subsidiaries, and affiliates and with other third parties who we think may offer or enable you to become aware of Experiences that may be of interest to you.
How to Opt-Out of Sharing for Marketing. If you do not wish to have PII such as your name, email address, postal address or phone number shared with third parties for their marketing purposes, contact our Privacy Policy Coordinator as described at the end of this document. But note that, in order for us to properly administer the Service, we must continue to share your Data with Third Party Providers as described in Section IV(C) above (if you object to such sharing, you should not use the Service). Note also that this option to opt-out applies only to PII, and not Anonymous Data.

How to Opt-Out of Marketing Messages from Us. If you do not wish to receive future marketing or other commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. But note that you may continue to receive certain communications from us that are necessary for the Service, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.

How to Update Your PII. If you have registered on any part of the Service, please use the mechanism or contact information on the Service that allows you to change or update your member preferences, if available, to keep all such Data accurate and up-to-date. If no such mechanism or contact information is available on the Service, contact our Privacy Policy Coordinator as described below with your changes.

Section 6: Cookies and Related Technologies; Do Not Track (DNT)
Cookies/Local Device Storage. The Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third Party Providers may use Local Device Storage in connection with the Service for any lawful business purpose, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control the display of ads, to track the movements of individual users through the Service and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Service. For example, if you register on any part of the Service and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your PII, which may be shared with our parent, subsidiaries, and affiliates and other third parties.

You May Disable Local Device Storage. If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Service may not function properly.

Tracking Technologies. In addition to Local Device Storage, we may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka “Machine Identification”) and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”) on the Service and in our communications with you, such as within e-mail and text messages and push notifications. We use Tracking Technologies to determine which of our messages have been opened by recipients, and for all or some of the same lawful business purposes we describe above for use of Local Device Storage.

Do Not Track (DNT). Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Service receives a DNT signal from a visitor’s browser. As discussed below, you may opt out of the use of your Data for online behavioral advertising by third parties at any time. To find out more about DNT, please visit http://allaboutdnt.com.

Section 7: Online Behavioral Advertising (OBA) and How to Opt-Out of OBA

How OBA Works. We and our Third Party Providers will at times also use Tracking Technologies for purposes of “online behavioral advertising” (OBA). OBA allows the serving of advertisements tailored to interests you have shown by browsing on the Service and on other sites, applications, destinations and services, using the sam or a different device. To enable OBA, we and Third Party Providers use Tracking Technologies to collect data including, for example, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by Third Party Providers is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith.
Opt-Out of OBA. If you do not want OBA, you may be able to opt-out by visiting http://www.aboutads.info, http://www.networkingadvertising.org, http://www.youronlinechoicees.com/uk/ and/or by clicking the “Ad Choices” icon that appears in advertising served through OBA. Please note that the option to opt-out applies only to tracking by Third Party Providers across this Service and other sites, applications, destinations and services, and not tracking among pages within the Service itself. Residents of the European Economic Area (EEA) and Switzerland have additional options as described below in Section XII(B) to exercise choices with respect to OBA.

Section 8:. Transfer of Your Data Among Jurisdictions
We are a U.S.-based company. Your Data may be processed, transferred to, and maintained on, servers and databases located within the U.S. and elsewhere where the privacy laws may not be as protective as your jurisdiction. We reserve the right to transfer your Data to and from any state, province, country or other governmental jurisdiction. Your consent to this Privacy Policy followed by your submission or our collection of such Data represents your agreement to any such transfer.

Section 9: Data Security and Notification
Security Measures. We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, PII that you share with us.

No Liability for Breach. Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the Data that you send to us or the security of servers, networks or databases, and by using the Service you agree to assume all risk in connection with your Data. We are not responsible for any loss of such Data or the consequences thereof.

Breach Notification. In the event that we believe the security of your Data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by e-mail, push notification, or otherwise.

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If you don’t agree to the terms contained in this Privacy Policy, you must immediately exit the Service.

Terms and Conditions

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Terms & Conditions

Introduction

These terms and conditions govern your use of this website, app and all platforms now and in future use; by using this website, app and all platforms now and in future use, you accept these terms and conditions in full. If you disagree with these terms and conditions or any part of these terms and conditions, you must not use this website, app and all platforms now and in future use.

You must be at least [18] years of age to use this website. By using this website and by agreeing to these terms and conditions you warrant and represent that you are at least [18] years of age.

[This website uses cookies. By using this website and agreeing to these terms and conditions, you consent to our SEPI’s use of cookies in accordance with the terms of SEPI’s privacy notice.]

License to Use Website

Unless otherwise stated, SEPI, LLC (“SEPI”) and/or its licensors own the intellectual property rights in the website and material on the website. Subject to the license below, all these intellectual property rights are reserved.

You may view, download for caching purposes only, and print pages [or [OTHER CONTENT]] from the website for your own personal use, subject to the restrictions set out below and elsewhere in these terms and conditions.

You must not:

republish material from this website (including republication on another website);

sell, rent or sub-license material from the website;
show any material from the website in public;
reproduce, duplicate, copy or otherwise exploit material on this website for a commercial purpose; or
edit or otherwise modify any material on the website.

Acceptable Use

You must not use this website in any way that causes, or may cause, damage to the website or impairment of the availability or accessibility of the website; or in any way which is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity.

You must not use this website to copy, store, host, transmit, send, use, publish or distribute any material which consists of (or is linked to) any spyware, computer virus, Trojan horse, worm, keystroke logger, rootkit or other malicious computer software.

You must not conduct any systematic or automated data collection activities (including without limitation scraping, data mining, data extraction and data harvesting) on or in relation to this website without SEPI’s express written consent.

You must not use this website to transmit or send unsolicited commercial communications.

Restricted Access

SEPI reserves the right to restrict access to [other] areas of this website, or indeed this entire website, at SEPI’s discretion.

If SEPI provides you with a user ID and password to enable you to access restricted areas of this website or other content or services, you must ensure that the user ID and password are kept confidential.

SEPI may disable your user ID and password in SEPI’s sole discretion without notice or explanation.

User Content

In these terms and conditions, “your user content” means material (including without limitation text, images, audio material, video material and audio-visual material) that you submit to this website, for whatever purpose.

You grant to SEPI a worldwide, irrevocable, non-exclusive, royalty-free license to use, reproduce, adapt, publish, translate and distribute your user content in any existing or future media. You also grant to SEPI the right to sub-license these rights, and the right to bring an action for infringement of these rights.

Your user content must not be illegal or unlawful, must not infringe any third party’s legal rights, and must not be capable of giving rise to legal action whether against you or SEPI or a third party (in each case under any applicable law).

You must not submit any user content to the website that is or has ever been the subject of any threatened or actual legal proceedings or other similar complaint.

SEPI reserves the right to edit or remove any material submitted to this website, or stored on SEPI servers, or hosted or published upon this website.

No Warranties

This website is provided “as is” without any representations or warranties, express or implied. SEPI makes no representations or warranties in relation to this website or the information and materials provided on this website.

Without prejudice to the generality of the foregoing paragraph, SEPI does not warrant that:

this website will be constantly available, or available at all; or
the information on this website is complete, true, accurate or non-misleading.

Nothing on this website constitutes, or is meant to constitute, legal advice of any kind. If you require advice in relation to any legal matter you should consult an appropriate professional.

Limitations of liability

The services and experiences described, and articles used in SEPI are provided without any guarantees or warranty by or from SEPI. No representation or warranties, either express or implied, of merchantability, fitness for a specific purpose of any service, experience or related to any article are made by SEPI. Use of the service or any element of any article are at the reader’s risk.
SEPI will not be liable to you (whether under the law of contact, the law of torts or otherwise) in relation to the contents of, or use of, or otherwise in connection with, this website:

to the extent that the website is provided free-of-charge, for any direct loss;
for any indirect, special or consequential loss; or
for any business losses, loss of revenue, income, profits or anticipated savings, loss of contracts or business relationships, loss of reputation or goodwill, or loss or corruption of information or data.

These limitations of liability apply even if SEPI has been expressly advised of the potential loss.

Reasonableness

By using this website, you agree that the limitations of liability set out in this website disclaimer are reasonable.

If you do not think they are reasonable, you must not use this website.

Other Parties

You accept that, as a limited liability entity, SEPI has an interest in limiting the personal liability of its officers and employees. You agree that you will not bring any claim personally against SEPI’S officers or employees in respect of any losses you suffer in connection with the website.

Without prejudice to the foregoing paragraph, you agree that the limitations of warranties and liability set out in this website disclaimer will protect SEPI’S officers, employees, agents, subsidiaries, successors, assigns and sub-contractors as well as SEPI.

Unenforceable provisions

If any provision of this website disclaimer is, or is found to be, unenforceable under applicable law, that will not affect the enforceability of the other provisions of this website disclaimer.

Indemnity

You hereby indemnify SEPI and undertake to keep SEPI indemnified against any losses, damages, costs, liabilities and expenses including without limitation legal expenses and any amounts paid by SEPI to a third party in settlement of a claim or dispute SEPI arising out of any breach by you of any provision of these terms and conditions, or arising out of any claim that you have breached any provision of these terms and conditions.

Breaches of these terms and conditions

Without prejudice to SEPI’s other rights under these terms and conditions, if you breach these terms and conditions in any way, SEPI may take such action as SEPI deems appropriate to deal with the breach, including suspending your access to the website, prohibiting you from accessing the website, blocking computers using your IP address from accessing the website, contacting your internet service provider to request that they block your access to the website and/or bringing court proceedings against you.

Variation

SEPI may revise these terms and conditions from time-to-time. Revised terms and conditions will apply to the use of this website from the date of the publication of the revised terms and conditions on this website. Please check this page regularly to ensure you are familiar with the current version.

Assignment

SEPI may transfer, sub-contract or otherwise deal with SEPI’s rights and/or obligations under these terms and conditions without notifying you or obtaining your consent.

You may not transfer, sub-contract or otherwise deal with your rights and/or obligations under these terms and conditions.

Severability

If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

Entire agreement

These terms and conditions, together with Privacy Note, constitute the entire agreement between you and SEPI in relation to your use of this website, and supersede all previous agreements in respect of your use of this website.

Law and jurisdiction

These terms and conditions will be governed by and construed in accordance with Washington state law, and any disputes relating to these terms and conditions will be subject to the exclusive jurisdiction of the courts of the state of California.

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