Privacy Policy 

Last Updated:  January 6, 2020 

Warm Commerce, Incorporated (“Warm Commerce”, “we” or “us”) values individual privacy, and we are committed to protecting individuals’ information. We are also committed to keeping you as an individual user (“you”) informed about how we collect and use information about you. 

This Privacy Policy (this “Policy”) is provided to inform you about Warm Commerces practices regarding collection, use, disclosure, processing and storage of information, and how you can contact us with any questions about our information practices or to access or request changes to information about you.  

Please review this Policy carefully to understand our practices, and how we collect and use personal information. If this Policy is unacceptable to you or if you do not agree with our information practices, you may choose not to visit our websites and not to use any services that we offer. 

If you have any questions or concerns that are not addressed here, please contact us at info@warmcommerce.com or as provided below1

 

1. Scope of this Policy 

This Privacy Policy applies to information that we collect from you through:  

    • public websites of Warm Commerce, at warmcommerce.com, and any Warm Commerce websites that directly link to this Policy (collectively, the “Sites”); and 
    • any other features, communications, content, downloads, products or services that are produced, provided, operated or maintained by Warm Commerce or on behalf of Warm Commerce, including your interactions with Warm Commerce personnel (collectively and together with the Sites, the “Services”). 

In addition, this Policy includes any separate privacy notices and/or notices relating to personal data that may be posted on or within certain Sites, or disclosed to users as part of specific Services. Such separate notices may provide additional details regarding information that we collect via those certain Sites or Services, the purpose of collecting that information, and choices you may have about the ways we use that information. 

This Policy does not apply to information collected by third parties, third-party websites, or content or applications of third parties, including any that may be linked to or accessible from the Services. 

 

 2. Information We Collect and How We Collect It 

Warm Commerce collects information using the Services through various means. 

(a) Information that You Provide to Us  

Warm Commerce collects information that you provide to us through the Services. For example, to use certain of the Services, you may be required to provide information about yourself, which may include your first and last name, email address, telephone number, home or work address, employer, professional title, age, gender, etc. We may ask you to provide information in the following situations: 

      • When you register for a user account on the Services 
      • When you use the Services 
      • When you submit payment for the Services 
      • When you submit content to the Services 
      • When you request Warm Commerce to provide information or alerts to you 
      • When you communicate with Warm Commerce for any other reason 

In these cases, you will know what information is collected through the Services because you will actively provide that information to us. 

Certain of the Services require specific personal information from you in order to utilize the Services.   

If there is information that you are required to provide to us or that we are required to collect, based on either law or contract, we will advise you of the requirement at the time we collect that information, and we will also provide information about any consequences of a failure to provide required information. 

Warm Commerce does not collect sensitive personal information, but in the event that we do collect any sensitive personal information, we will endeavor to provide additional appropriate disclosures and obtain your explicit consent as required by applicable law.

 

(b) Information that We Collect Automatically 

As part of the standard operation of the Services, Warm Commerce automatically collects information from your computer or device about your activities relating to the Services. This may include, for example: 

      • Device and technical information such as IP address (a numerical value used to identify a computer within a network), geographical location, information about the type of device or platform used (a Google browser or an Apple platform, for example), device identifiers and browser information 
      • Browsing information such as domain name (that you accessed the Services from www.company.com, for example), referral or exit data (the last website that you visited before coming to the Services and the next website you visit afterwards, respectively) and language 
      • Information and analytics about how you use the Services, such as date and time, how often and the amount of time you spend using the Services, the areas of the Services that you spend the most time on, and other click-stream data  

Information collected automatically is generally statistical data, and it does not necessarily identify you personally. 

 

(c) How We Use Cookies and Other Tracking Technologies 

Like many websites and applications, Warm Commerce uses cookies and other tracking technologies to help tailor the Services to the needs and interests of users and to improve users’ experience of the Services, as well as for systems administration, troubleshooting, and security purposes. A cookie is a small text file stored on your device or computer when you access the Sites or Apps. These small text files allow the Site or App to recognize your computer or device at the next visit and remember your preferences and information (for example, your login, language, font size and other display preferences). This way, you do not need to re-enter that information whenever you return or browse from one page to another within the Services. Cookies may also be used by a website to collect data about user activity, or how the website is used by visitors  

There are two basic types of cookies: Session cookies are temporary files that are cleaned up (deleted) when close your browser program. Persistent cookies store your information and settings for longer periods, in order to remember your information and preferences between visits to a website. In providing the Services, we use both types of cookies for the following purposes: 

      • Preferences. We use cookies to remember you, including your information and preferences, so that you do not have to enter information every time you use the Services. 
      • Authentication. We use cookies to authenticate customers when they log into certain of our Services. These cookies are necessary for you to use those Services. 
      • Analytics. We use cookies to better understand how people are using the Service, by gathering information described above about usage. 

To learn more about management of cookies, see our Cookies Statement at [URL link to Cookies Statement] and see Your Choices2 below. 

To develop information about activity related to the Services, Warm Commerce may also use a small file, called a web beacon. Web beacons do not by themselves collect any personal information from users, but in combination with cookies, web beacons allow Warm Commerce to track, for example, whether web pages are viewed, how often web pages are viewed, and the specific times of day web pages are viewed. 

We also use Google Analytics, an analytics service provided by Google, in offering our Services. Google Analytics uses cookies and other tracking technologies to help us analyze how users interact with and use the Services, and to compile activity reports and provide other, related services based on users’ activities and usage. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies (available at policies.google.com/privacy). To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, see Your Choices3 below or go to policies.google.com/technologies/partner-sites. 

In addition, we may partner with third-party advertising companies and others to collect or use information about you and about individuals who use our Services, and to provide advertisements about our goods and services that may be of interest to you. These third parties may use technologies such as cookies, web beacons, tags or other technologies to collect information about you when you use our Services. These third parties may also collect information about you and your activities across different websites, apps and other online services, and they may use persistent identifiers to collect and correlate this information. These third parties may use information about you to provide you with targeted advertising or content based on your interests and activities. For information about opting out of or managing the collection or use of such information, please see Your Choices4 below. 

 

3. How We Use Information We Collect 

Warm Commerce uses information that we collect, including personal information about you, to provide the Services to you and to continually evaluate and improve the Services we offer.

(a) General Uses of Information 

          We may use personal information about you for the following general purposes: 

      • To provide our Services according to your requests 
      • To present information or content that you may access on via the Services, including personalization of such information and content 
      • To process transactions, including financial transactions, related to your use of the Services 
      • To communicate with you about your user account or transactions with Warm Commerce and to send you information and announcements about the Services, or about features or improvements 
      • To optimize and improve our Services and operations, for example by analyzing usage of or interest in features, identifying areas of interest, or providing updates to the Services 
      • To maintain our Services, operations and any content or information provided through our Services 
      • To respond to your questions or requests for information, or to fulfill any other purpose for which you provide your information to us through the Services 
      • To provide you with information about our Services, or updates, editorial content, industry education, invitations to upcoming events or similar information 
      • To detect, investigate and prevent activities that may violate our policies or that may be harmful or illegal 
      • To perform statistical, demographic, marketing or other analyses of users of the Services or to investigate relevant industries and markets 
      • To better understand how visitors and users interact with the Services and the performance of the Services, including measuring and monitoring user traffic and using aggregate statistical analysis, which informs future enhancements and changes to the Services, or by combining information collected through the Services with information about our users collected by other means 
      • For any other purpose that we might describe at the time we collect your information 
      • For any other purpose with your consent 

(b) Combining Information about You   

We may combine information collected about you from Sites or otherwise across our Services, as well as information about you collected through off-line interactions or from third parties, into individualized user records, analyses or reports, or we may combine such information into aggregate reports or analyses.  

 

4. How We Disclose Information 

Warm Commerce may disclose aggregate statistical information about our users, which does not identify individual users, without restrictions. 

Warm Commerce may also share personal information about you to deliver any requested information, products, or services to you, or otherwise to fulfill a contractual obligation to you. 

(a) Disclosures of Personal Information 

Personal information about you, i.e., information that identifies or may identify you individually, that you provide or that we collect as described in this Policy, may be disclosed to third parties as follows: 

      • Third Parties You Engage via the Services. In some cases, the Services facilitate communications between you and third parties. In those cases, if you engage with the third party via the Services, then we will provide personal information about you to that third party 
      • Third Party Agents of Warm Commerce. We may share personal information about you with our third party service providers, who perform functions on our behalf, such as hosting, billing, payment processing, analytics, notifications, content management, customer service, etc. These third party agents are bound by confidentiality obligations, and they are only permitted to use any personal information we share with them in connection with services they provide to us. For example, we may store your data on servers that are owned and operated by our hosting services provider. 
      • Trusted Business Partners. We may provide personal information about you to our trusted business partners, to enable them to provide you with information about other products or services offered by those business partners that you may be interested in(If you do not wish to receive these kinds of communications, please see Your Choices5 below for information about opting out of these communications. 
      • Warm Commerce Entities. We may share personal information about you with Warm Commerce subsidiaries and affiliates. 

Warm Commerce may also disclose personal information about you in the following circumstances: 

      • As required by law, court order, or legal process, including to respond to a subpoena, to respond to a government or regulatory request, or to cooperate with law enforcement investigations. 
      • To enforce our contractual rights, take precautions against liability, investigate suspected or actual illegal activities, or to investigate and defend ourselves against third-party claims or allegations. 
      • To a buyer or other successor in the event of a merger, restructuring, reorganization, or other sale or transfer of some or all of our assets, including, but not limited to, as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of the Services is among the assets transferred. 
      • When we believe that disclosure is necessary or appropriate to protect the rights, property, or personal safety of ourselves, our customers, or others. 

Warm Commerce may also share personal information about you in ways that may be described later, with your consent, or as otherwise described in this Notice. 

Whenever we disclose personal information to a third party, we seek to minimize the disclosure to only information that is necessary for the purpose of that disclosure. 

          (b) Disclosures of Statistical or De-Identified Information 

Warm Commerce also uses statistical and aggregate information about users, as well as de-identified information (together referred to as “aggregate information”).  This aggregate information does not identify specific individuals and could not be traced to specific individuals.  

We may use and disclose aggregate information without restrictions and for a broad range of purposes, including, without limitation, the following: 

      • Tanalyze and share characteristics of users of the Services, which may be used to improve the Services or its features, for example by attracting third parties to list their products and services through the Services, or to better market the Services.
      • Tdevelop and publish industry research and reports.

 

5. How Long We Keep Personal Information 

Warm Commerce maintains personal information about you for as long as you maintain a user account, as long as needed to provide the Services to you, or with your consent, we may continue to maintain information about you for our internal business purposes.  

We may also retain personal information about you for a reasonable time for backup, archival, reactivation or audit purposes, or as needed to comply with our legal obligations, resolve disputes or enforce our agreements. If you have any questions about how long we may keep personal information about you, please contact us at info@warmcommerce.com or as provided below6. 

 

6. International Transfers of Personal Information  

For the purposes described in this PolicyWarm Commerce may transfer information across borders, including from your country or jurisdiction to other countries or jurisdictions around the world, where applicable laws may not provide the same level of protection of personal information as the laws of the country or jurisdiction where you are located. In those cases, we take steps to ensure that information will be provided the same level of protection in the recipient country or jurisdiction.  

By visiting or using the Services, you hereby consent to the transfer of your personal information to countries where applicable laws may not provide the same level of protection of personal information as the laws of the country or jurisdiction where you are located, including, without limitation, the United States, in accordance with this Policy.   

Please do not provide information to us, either directly or indirectly, and do not use the Services if you are located in a country or location where this Privacy Policy violates local laws or regulations, or the use of the Services is not permitted. 

 

7. Accessing and Requesting Changes to Personal Information 

If you have registered to use the Services, you can review and change your personal information through your user account. 

If you have not registered to use the Services or cannot access or change certain of your personal information through your user account but still wish to access, correct, update, or delete personal information about you, please send us your request via info@warmcommerce.com, or as provided below7. Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity, or take other actions that we believe are appropriate in order to verify your identity. 

Please understand that we may not be able to alter or delete your personal information if we are required under applicable law to maintain that information. We are also not obligated to comply with requests that are unreasonably burdensome or expensive, or with requests that would interfere with the rights of another individual. In some circumstances, we may charge a reasonable fee to fulfill your request. 

 

8. Your Choices 

You have certain choices about how personal information about you is collected, used and shared. Although you cannot opt out of all collection or use of personal information and still use the Services, you can take steps to limit or control how personal information that identifies you is collected, used and shared. 

(a) Cookies 

You can control or delete cookies, or otherwise manage cookies, through your browser or device settings. For more details, please visit http://www.allaboutcookies.org or http://www.aboutcookies.org. 

However, please understand that if you limit or reject cookies, although you may still access some of the Services, certain functions will be affected. You may not be able to log into or access certain Services unless you accept cookies. 

To learn more about our use of cookies and how to manage cookies, see our Cookies Statement at https://www.warmcommerce.com/cookies-policy

(b) Advertising Partners 

Warm Commerce has engaged third parties to manage our advertising on other sites, and they may collect information and provide advertising to you based upon your browsing activities and interests.  

We do not control these third parties’ tracking technologies, how they may be used or the information they may collect, and we are not responsible for their privacy policies or the content that may be provided by those third parties. You can learn more about online and interest-based advertising, including about choices available to you, at http://www.aboutads.info/consumers. 

If you prefer not to have information used for the purpose of serving you personalized advertising, you may also learn more about your choices or change your preferences at http://optout.aboutads.info, http://optout.networkadvertising.org, http://preferences-mgr.truste.com,  from Google at http://www.google.com/settings/ads or http://policies.google.com/technologies/partner-sitesfrom Facebook at http://www.facebook.com/about/ads/ or http://www.facebook.com/policy.phpor if you are located in the European Union at http://www.youronlinechoices.eu/. 

(c) Email and Other Communications 

If you would like to change the types of communications you receive from us or how you receive communications from us, including opting out of promotional communications, you may do so at any time by updating the communication preferences provided in your user accountIf you have not registered or do not have a user account, you may also use the opt-out link and instructions that will be present in any promotional emails that we send. 

Please understand that, even if you opt out of marketing communications, Warm Commerce may continue to send non-promotional communications such as confirmations of transactions, changes to the Services or other information about your use of the Services 

(d) The Sites do not respond to “do-not-track” requests or similar browser settings. 

 

9. Security 

Warm Commerce strives to use commercially reasonable means and to follow generally accepted industry data practices to protect the personal information submitted to us from accidental loss and from unauthorized access, use, alteration, and disclosure.  

However, no physical or electronic security system is impenetrable, and there is no completely secure or error-free method of data transmission over the Internet.  As such, Warm Commerce cannot and does not guaranty security of personal information about you, nor can Warm Commerce guaranty that information you supply won't be intercepted while being transmitted to Warm Commerce over the internet or other networks.   

You are also responsible for the safety and security of your information. It is your responsibility to keep secret any username and password that you use to log into or access and of the ServicesYou should also adopt strong passwords that others cannot easily guess. Please do not share this information with any other person, and remember that you are responsible for any use of the Services when they are accessed with your username and password or under your user account. If you ever suspect or believe that your username or password have been compromised or used by somebody else, please promptly tell us by emailing us at info@warmcommerce.com or as provided below8

 

10. Children’s Privacy 

The Services are not intended for children under the age of 13 or as defined by applicable local law, and children should not use the Services for any purpose, even with permission of a parent or other responsible adult.  

Warm Commerce does not knowingly collect or solicit personal information from children. If we learn that we have collected or received personal information from a child, we will delete that information. If you believe that we may have any personal information about a child, please contact us at info@warmcommerce.com or as provided below9 

 

11. Changes to this Privacy Policy 

Warm Commerce may update this Privacy Policy to reflect changes to our information practices. If we make material changes to this Policy, we will provide notice to you by changing the “Last Updated” date at the top of this Policy.  

We encourage you to periodically review this Privacy Policy to learn of any changes to how we treat the personal information with respect the Services. 

 

12. Contact Us 

Please feel free to contact us with any questions, comments, complaints, or suggestions regarding this Privacy Policy or our information practices. You can contact us by email at info@warmcommerce.com or by postal mail at: 

Warm Commerce, Incorporated. 

1301 Fannin St, Suite 2440 

Houston, TX, 77002