Privacy Policy

This Privacy Policy was last revised April 30, 2019

 

This privacy policy describes how we treat and use the information we collect when you visit or use our website (the “Website”).  Manifest LLC (“we,” “us,” “our” or “ours”), located at 228 E. 45th Street, 7th Floor, New York, NY 10017, owns and operates the Website.  This Website is operated in the United States and in accordance with the laws of the United States.

 

We provide you this privacy policy to help you understand the kinds of personal information we may gather about you when you visit the Website or use any of its services, how we may use and disclose that information, and how you can control, correct and/or update that information.

 

As used in this privacy policy, “personal information” means any information or set of information about an identified or identifiable natural person, where an identifiable natural person is one who can be identified by all means reasonably likely to be used by any person to identify the natural person directly or indirectly.  “Personal information” does not include information that is not associated with an identified or identifiable individual or information that is reported in the aggregate (provided that such aggregated information is not identifiable to a natural person), and does not include “anonymous” information, by which we mean information as to which identifying characteristics have been removed without means reasonably likely to be used by any person to re-identify the natural person directly or indirectly.

 

By visiting the Website or using the services, you are accepting the policies and practices described in this privacy policy.  Each time you visit the Website or use the services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this privacy policy.

 

Personal Information that We Collect

 

Information You Provide. We collect personal information that you voluntarily provide. The only personal information we may collect is your email address, which we will collect only if you choose to sign up for our newsletter.

 

Location Information and IP Address. We and our service providers and advertisers may collect and share your location for personalization and marketing purposes using certain digital applications, wireless access protocol services (“WAP Services”) or mobile phone services. We, and/or our service providers, will obtain your prior consent to such collection to the extent required by applicable law. An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. We and/or our service providers may use your IP Address when you access the Website or use other means to assist with delivering geographically targeted advertisements. For more information, please see the section  below in this privacy policy entitled “Cookies and Targeted Advertising”.

 

General Usage Information. We may gather usage information about Website users on an anonymous basis. Examples of such information include amount of time spent on our Website, pages viewed, websites users originated from and websites users visit after leaving our Website. This information helps us create a faster, efficient and more relevant website.

 

Cookies and Targeted Advertising

We may use small pieces of information placed on your browser, known as “cookies”, to provide you with a more personal and interactive experience. We may use cookies to determine what advertisements you see, control the sequence of advertisements and make sure you do not see the same advertisement too many times. We may use cookies along with pixels, web beacons (which are usually small, transparent graphic images), operating system and device information and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit to our Website, the features and information for which you searched and viewed on our Website, the email you opened (if you choose to sign up for our newsletter), or on which advertisements you clicked. Companies we work with may also use cookies for understanding Web usage patterns of users who see advertisements on the Website. We do not store personal information in any cookies that are placed on your computer.

 

Cookies can be removed by following your Internet browser’s directions, which are usually within the help menu. However, please understand that in order to use certain features of the Website, your web browser must accept cookies. If you choose to disable cookies, some aspects of the Website may not work properly, and you may not be able to access the Website.

 

We believe that advertising is more interesting to you when it is relevant. Accordingly, we customize the advertisements that you see based upon: (i) geographic location information, which we may determine through your IP address or other ways; (ii) data we receive from third parties; and (iii) your visits to the Website or use of other services (commonly referred to as behavioral advertising or interest-based advertising). We may use your personal information to deliver customized advertising to you on this Website, on other websites and on other digital and offline media channels. We may use third-party vendors to connect information that we collect on the Website (such as IP addresses, geo-location, cookie-related data, and other information described above) with information collected from other websites, devices and media channels and then show you advertising based on this combined information. The advertisement may appear when you are visiting a different section of the Website or another website, device or media channel.

 

If you would like more information about behavioral advertising and/or more information so that you may better know your choices with respect to such advertising, please visit www.aboutads.info/choices. Many vendors that engage in behavioral advertising participate in the Network Advertising Initiative (NAI) and/or the Digital Advertising Alliance (DAA) and abide by NAI and/or DAA principles. If you wish to opt out of participating in advertising programs conducted by NAI and DAA members or learn more about the NAI and DAA, please go to the NAI Opt-Out website or DAA Ad Choice Page and follow the instructions. After you opt-out, you will still see advertisements, but the advertising may not be as relevant to your interests. If you change your computer, change your browser or delete your cookies, you may need to renew your opt-out. For opt-out options specific to Google Analytics, please visit tools.google.com/dlpage/gaoptout. If you delete your cookies or upgrade your browser after having opted out, you will need to opt out again. If you use multiple browsers or devices, you will need to re-submit this opt-out on each browser or device.

 

Advertisers or other third parties on the Website may also engage in behavioral advertising and use cookies and web beacons in similar manners as the ways described above. We do not control these advertisers or other parties’ use of cookies or web beacons or what they do with the information they collect. 

 

We may use Facebook to deliver ads on the Website. Facebook may use information you share on Facebook and information gathered from your use of other websites and apps to delivery ads to you. To learn more about this type of advertising and your choices about it, visit www.facebook.com/about/ads.[AM1] 

 

Our Website is currently not setup to respond or process web browser “Do Not Track” (“DNT”) signals.[AM2] 

 

Use of Information

 

We may use personal information that we collect from you for the following purposes:

 

  • to respond to your requests, resolve problems, provide our services including to measure or understand the effectiveness of our services, provide our Website to you, improve our offerings and to create new services;

 

  • to send you promotional/marketing information, newsletters, offers or other information regarding opportunities and functionality that we think would be of particular interest to you;  
  • to fulfill any other purpose for which you provide the information; for example, to respond to you if you contact us with any questions;  
  • to notify you, at our discretion, about changes to our Website or any products or services we offer or provide though it;  
  • to analyze, benchmark and conduct research of user data and user interaction with the Website and to gain insights that help us to make improvements to the design and performance of the Website;  
  • in any other way we may describe when you provide the information; and  
  • for any other purpose with your consent or as permitted by law.  

We may disclose and release your personal information to third parties:

 

  • to enable third party service providers to provide products, services or functions on our behalf or to help us to operate our business and the Website;  
  • to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order;  
  • in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or in any cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or violation or alleged violation of this privacy policy or other agreement we may have with you;  
  • to enforce our Terms of Use [PLUM TERMS OF USE LINK];  
  • with your consent or in accordance with your indicated preferences (e.g., you indicated to receive materials directly from a third party partner);  
  • to respond to your requests for customer service; and  
  • in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock or otherwise) of all or a portion of our business or of the division or portion of our business conducted by the Website, in which case the acquiring company will possess the information collected by us.  

We may also disclose your information to any of our subsidiaries, affiliates or parent companies.

 

We may share anonymous information about you with third parties for any purpose.  This includes Google Analytics, with whom we share may anonymous information to analyze the audience of the Website and improve our content. No personal information is collected from Google Analytics. For further information on the privacy policy concerning Google Analytics, please go here, support.google.com/analytics/answer/6004245?hl=en

 

If you do not want us to use or disclose personal information collected about you in the ways identified if this privacy policy, you should not use the Website or services.

 

Accessing and Controlling Your Information

Under laws in certain countries in which we operate, visitors to our Website from those countries have a right to access personal information about themselves, and to amend, correct or delete personal information that is inaccurate, incomplete or outdated.  We will, upon request, provide you with confirmation regarding whether we are processing personal information about you, consistent with applicable law. In addition, upon your request, we will take reasonable steps to correct, amend, or delete your personal information that is found to be inaccurate, incomplete or processed in a manner non-compliant with this privacy policy or applicable law, except where the burden or expense of providing access would be disproportionate to the risks to your privacy, where the rights of persons other than you would be violated or where doing so is otherwise consistent with applicable law. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of personal information that you request.

 

Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all personal information for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

 

You authorize us to use and disclose any new or modified information that you provide in accordance with this privacy policy, and you agree that we are under no obligation to delete or modify information that you have previously chosen to provide us as to which you have not instructed us to take such action. Please remember, however, that if we have already disclosed some of your personal information to third parties, we cannot access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

 

We may retain your personal information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.

 

How to Opt Out

You can unsubscribe from receiving our newsletters or commercial emails at any time. You can unsubscribe by clicking on the “Unsubscribe” link in the footer of any of our emails and following the instructions.

 

Third Parties Not Governed by this Privacy Policy

This privacy policy addresses only our use and disclosure of information we collect from or about you. The use and disclosure restrictions contained in this privacy policy do not apply to any third party and we do not control the privacy policies of third parties. The Website and our services may contain links to other sites and resources controlled by third parties. In addition, if you disclose information to others, including to other uses, you are subject to the privacy policies or privacy statements of those third parties where applicable.  We are not responsible for the privacy practices or content of these other sites or resources, and you should consult the privacy policies or privacy statements of such other sites and resources.

 

Data Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. Taking into account the risks involved in the processing and the nature of the information we process, We maintain appropriate administrative, technical and physical safeguards to protect information in our possession against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing. This includes, for example, firewalls, password protection, encryption and other access and authentication controls.

 

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on our services or the Website, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your information has been compromised, please contact us as set forth in the “Contact Us” section below.

 

We have a security incident response program designed to promptly respond to and escalate any potential privacy or security incident.  If we learn of a security incident, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

 

Personal Information Processed in the USA and Elsewhere

The Website is hosted and our services are provided in the United States of America. In the performance of our services and business operations, personal information we collect or receive may be stored or transferred internationally throughout our organization and to our service providers or agents, in accordance with applicable data privacy laws.  Transfers to third parties are covered by the provisions in this privacy policy under “Use of Information”. 

 

We will endeavor to obtain assurances that any such service provider or agent will provide at least the same level of privacy protection as is required by this privacy policy and will notify us if it makes a determination it can no longer meet this obligation.

 

We use model contractual clauses and other mechanisms approved by the European Union and Switzerland, respectively, for transfers of personal information from the European Economic Area and Switzerland. 

 

Where we know that any third party to whom we have provided personal information is using or disclosing personal information in a manner contrary to this privacy policy, we will take reasonable steps to prevent or stop the use or disclosure. With respect to such onward transfers to agents, and to the extent we are responsible for the event, we will remain liable should our agents process personal information in a manner inconsistent with this privacy policy.

 

Children

We do not offer the Website to anyone under the age of majority in their jurisdiction of residence and do not knowingly collect personal information from children under 13. No one under age 13 may provide any information to or on the Website. If you are under 13, do not use or provide any personal information on or through the Website, register on the Website, or use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, email address or any screen name or user name you may use.

 

If you are the parent or guardian of a child whom you believe has disclosed personal information to us, please contact us as set forth in the “Contact Us” section below so that we may delete and remove such child’s information from our systems. In addition, in the event that a minor under the age of 18 in California uses the Website, the minor may request that we remove content or information posted by the minor on the Website by sending an email to as set forth in the “Contact Us” section below. However, such removal may not remove all traces of such posting everywhere online, since content or information may have been shared by others. We may not have to comply with this removal requirement if: (i) federal or state law requires that we maintain the content or information; (ii) the content was stored or posted (or reposted) by a third party other than the minor contacting us; (iii) we anonymize the content or information so that the minor cannot be identified; (iv) the minor received compensation or other consideration for providing the content; or (v) the minor does not follow the instructions in this section.

 

Your California Privacy Rights: Notice to California Customers

Subject to certain limits under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with (i) a list of certain categories of personal information that we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (ii) the identity of third parties that received personal information from us for their direct marketing purposes during that calendar year. The list will not be specific to disclosures your particular personal information. To make such request, send us an email or to us as set forth in the “Contact Us” section below, indicating “Your California Privacy Rights” in the subject of your email or letter, your name and complete mailing address. We are not responsible for requests that are not labeled or sent properly, or do not have complete information. Please note that we are only required to respond to one request per customer each year.

 

Jurisdictional Issues

We make no representation or warranty that the content and materials on the Website are appropriate or available for use in locations outside of the United States. Those who choose to access the Website or use the services from other locations do so on their own initiative and at their own risk, and are responsible for compliance with local laws, if and to the extent applicable.

 

Modifications

We may make changes to this privacy policy at any time. If and when we do, we will inform you by posting the revised privacy policy on the Website. You are responsible for periodically visiting our Website and this privacy policy to check for any changes. Any changes that are made to this privacy policy will apply to both any personal information that we hold prior to the effective date of the amended privacy policy and any personal information that we collect on or after such effective date. Your continued use of the Website after this privacy policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the privacy policy, as amended.

 

Contact Us

If you have questions about this privacy policy, or about the Website, please contact us at Manifest LLC, 228 E. 45th Street, 7th Floor, New York, NY 10017, or email us at [SUPPORT EMAIL].