Effective Date: April 22, 2021
Welcome. You have arrived at a website provided by Clean Path New York, LLC (CPNY). and/or one of its divisions, affiliates, subsidiaries, or joint ventures (“Clean Path New York, LLC (CPNY),” “Company” or “we,” “our” or “us”). We respect your privacy and want to protect your personal information.
What Information We Collect
1. Information You Provide to Us
In connection with the Services we provide, we may ask you to provide us with certain information, including (i) your first and last name, email address, home or business address, other shipping or billing addresses, telephone number, mobile number, username, or other information that could reasonably be used to identify you personally or identify your household or device (hereinafter, “Personal Information”); and/or (ii) demographic information, such as your country, state, or county of residence or business operation (“Demographic Information”).
We may collect this information when you:
- Request information from us via forms or emails, such as signing up for our newsletter or requesting information about a Location or a future Location;
- Contact us regarding a question, concern, or inquiry, such as when you make inquiries concerning our Sites, products and/or Services (including at in-person events such as open houses, or by phone or email);
- Register and create an account on our Site(s);
- Sign up or request to be placed on our mailing and/or email marketing lists;
- Sign up for free Wi-Fi at one of our Locations;
- Apply for employment with us;
- Provide billing information to us;
- Otherwise interact with the Sites or our representatives.
Your decision to provide us with information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all of the Site’s features or our Services.
2. General Browsing
In addition to information that you choose to submit to us, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site(s) or use Wi-Fi at any of our Locations (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site(s) or with Wi-Fi at one of our Locations. Usage Information may include:
- Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier (“Device Identifier”);
- Your Device functionality (including browser, browser language, operating system, hardware, mobile network information);
- Referring and exit web pages and URLs;
- The areas within our Site(s) that you visit and your activities there, including remembering you and your preferences;
- Your Device location or other geolocation information, including the zip code, state or country from which you accessed the Services;
- Your Device characteristics; and
- Certain other Device data, including the time of day you visit our Site(s).
For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you. If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.
We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site(s), include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
- Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of cookie technology to store information on local storage.
- Web Beacons. A Web Beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages and messages.
- Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.
- ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
- Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
- Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
We may use Tracking Technologies for a variety of purposes, including:
- To allow you to use and access the Site, including for the prevention of fraudulent activity and improved security functionality or to allow you to make use of cart or payment functionality;
- To assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site;
- To offer you enhanced functionality when accessing the Site, including identifying you when you sign into our Site or keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
- To deliver content relevant to your interests on our Site and thirdparty sites based on how you interact with our advertisements and/or content.
4. Information We Collect When You Interact with Third-Party Sites
5. Information from Third Parties.
In addition, we may collect information about you from other sources, including consumer credit reporting agencies, in order to evaluate your application for employment. We may also obtain information about you from marketers and market research firms. We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services.
Why We Collect Information
We may use your information for various purposes, including:
- Responding to your requests for information;
- Verifying your identity and for fraud prevention;
- Processing your payments or purchases;
- Analyzing and evaluating your employment application;
- Sending you email communications such as electronic newsletters about our products, Services, events, and promotions;
- Improving the effectiveness of our Site, our marketing endeavors, and our product and service offerings;
- Identifying your product and service preferences, providing personalized content and ads and informing you of new or additional information, products and services that may be of interest to you;
- Helping us address problems with and improve our Site and our products and services, including testing and creating new products, features, and services;
- Providing mobile marketing messages and other communications and messages;
- Protecting the security and integrity of the Site, including understanding and resolving any technical and security issues reported on our Sites;
- Engaging in analysis, research, and reports regarding the use of our Sites and Services;
- For internal business purposes;
- Complying with the law and protecting the safety, rights, property or security of Clean Path New York, LLC, the Services, and the general public; and
When We Disclose Information
We may aggregate, de-identify, and/or anonymize any information collected through the Site(s) or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.
Examples of when Clean Path NY, LLC may share your information include as follows:
- Third Parties Providing Services to Clean Path NY, LLC. We may use Third-Party Service providers to perform certain services on behalf of us or the Site(s) or Services, such as: (i) creating and updating Site(s) and app functionality; (ii) assisting us in Site(s) and app operations; (iii) managing a database of customer and consumer information; (iv) hosting the Site(s); (v) designing and/or operating the Site’s features; (vi) tracking the Site’s activities and analytics, including marketing and market research; (vii) data enhancement (to learn more about our customers); (viii) enabling us to send you special offers or perform other administrative services, such as customer service, security, tech, operational support, email and legal services; and (ix) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information to carry out the services they are performing for you or for us. Those vendors may have additional or different privacy policies and/or Terms of Service. You should be sure that you read and agree to those policies and Terms.
Ads and Information About You
You may see certain ads on our Site because we may participate in advertising networks administered by third parties. These networks track your online activities over time and across third party websites and online services by collecting information through automated means, including through the use of the Tracking Technologies described above, and they use this information to show you advertisements that are tailored to your individual interests. The information they collect includes information about your visits to our Site(s), such as the pages you have viewed. This collection and ad targeting takes place both on our Site(s) and on third-party websites that participate in the ad network. This process also helps us track the effectiveness of our communications and marketing efforts.
Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the particular website you are viewing (e.g., contextually based ads). Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective.
Your Choices About the Information We Collect and “Do Not Sell”
If you do not wish to receive e-mails about special offers, events, and other promotions from us, email us at email@example.com to opt out, or click the link in the email to “unsubscribe.”
Please note that certain of your personal information, such as your name or other identifying information, may remain in our database even after a deletion request in order to maintain the integrity and historical record of our database and systems.
Do Not Track Disclosures
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally-agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.
Visitors to the Site Outside of the United States
Updating Personal Information
We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at firstname.lastname@example.org.
If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons, such as a legitimate business reason.
In addition, please note that if you implement a deletion request but later sign up for information or Services, your most recent request will control our information relationship with you.
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Site, and you provide us with your information at your own risk.
International Data Transfers
Because Clean Path NY, LLC works with global companies and technologies, we may transfer your Personal Information outside of the country in which it was originally provided. This may include transfers to third parties, such as service providers or affiliated entities who are location outside the United States or the European Union, where data protection laws may not offer the same level of protection as those in the U.S., E.U. or European Economic Area (“EEA”). When we transfer personal data outside of these areas, we take steps to make sure that appropriate safeguards are in place to protect your Personal Information. Our transfers of your personal data outside of the E.U. are safeguarded by data processing agreements (“DPAs”) incorporating Standard Contractual Clauses. You may request a copy of the relevant portions of such agreements by contacting us at email@example.com. Please include the nature of your request in the subject line.
Your Data Protection Rights Under the General Data Protection Regulation (GDPR)
If you are a resident of or located within the European Economic Area (EEA), you have certain additional data protection rights. These rights include:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Information.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Clean Path NY, LLC relied on your consent to process your personal information.
Legal Basis for Processing Personal Information Under GDPR
Clean Path NY, LLC may process your Personal Information because:
- We need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our legitimate interests and it is not overridden by your rights; or
- To comply with the law.
Retention of Information
Clean Path NY, LLC will also retain Usage Data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
Transfer of Information
Your information, including Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to United States and process it there.
Disclosure of Personal Information
Disclosure for Law Enforcement - Under certain circumstances, Clean Path NY, LLC may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Clean Path NY, LLC may disclose your Personal Information in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Clean Path NY, LLC.
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Information
The security of your Personal Information is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Please note that we may ask you to verify your identity before responding to such requests.
Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first.
For more information, please contact your local data protection authority in the EEA.
Your California Privacy Rights – Privacy Notice for California Residents
Clean Path NY, LLC collects certain types of personal information about you during your relationship with Clean Path NY, LLC as a user, resident, owner, or visitor. Under California law, if you are a resident of California, you have the right to request certain information that we collect about you, including:
- The categories of Personal Information we have collected from you;
- The categories of sources from which we collected the Personal Information;
- The business purpose we have for collecting or sharing that Personal Information;
- The categories of third parties with whom we share such Personal Information; and
- The specific pieces of Personal Information we have collected about you.
In addition, you may request that we provide you with:
- The categories of Personal Information that we sold about you, and the categories of third parties to whom the personal information was sold, by category or categories of Personal Information for each category of third parties to whom the information was sold;
- The categories of Personal Information that we have disclosed about you for a business purpose;
- The category or categories of consumers’ Personal Information that we have sold, or if we have not sold consumers’ Personal Information; and
- The category or categories of consumers’ Personal Information that we have disclosed for a business purpose, or if we have not disclosed that information for a business purpose.
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
You may make a written request to us here to request this information. We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice a year. You may call, email or write us with your request at the contact information below. Please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident by including a California postal address in your request. We will respond to your request within 45 days or let you know if we need additional time.
Web Form for Access/Deletion/Do Not Sell Requests:
We may be unable to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Your Nevada Privacy Rights
If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from the Clean Path NY, LLC Site(s), you may ask us to disclose whether we have sold (for monetary consideration) certain information about you (including your first and last name, physical address, email address, telephone number, social security number, an identifier that allows you to be contacted either physically or online, or other contact information that allows us to identify you personally).
As a Nevada resident, you may also request to opt out of us sharing such information about you. To make this inquiry, please submit a request in writing to firstname.lastname@example.org with “Nevada Privacy Rights” in the subject line. You must include your full name, email address, and attest that you are a Nevada resident by providing a Nevada postal address in your request. Please state whether you are requesting information and/or opting out. [You must complete a separate request for each affiliated business.]
We will process your request within 60 days, or we will let you know if we need additional time. We may require additional information to verify your identity before we can respond.