Legal & Privacy

Last Updated: December 13, 2024

This online privacy notice (“Online Privacy Notice”) is being provided by the following companies (collectively, “Generational Gifting Inc”, “Generational Gifting Concept”, “we”, “us”, or “our”):

We are committed to maintaining your confidence and trust as it relates to the privacy of your information. Please read below and learn how we collect, protect, share and use your information as part of our technology platforms, including, without limitation, our websites, interactive features, applications, and social network pages (“Platforms”).

1. INFORMATION WE COLLECT ON OUR PLATFORMS

Information You Provide To Us

We may collect Personal Information (information that can be used to identify you as an individual) such as your name, email, telephone number, demographic information (such as state of residence, age), amount of children being gifted including your gifting budget as well as miscellaneous information you input into the form fill fields “describe your gifting goals” & “additional info (Optional)”. The types of Personal Information we collect may vary depending on your use of the features of the Platforms. 

Information We Collect Automatically

Usage Information. Whenever you visit or interact with the Platforms, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Platforms are accessed and used (“Usage Information”). Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on the Platforms. For example, we use session replay tools to record your interactions with the Platforms, such as how you move throughout our Platforms and engage with our webforms. We may also collect geolocation information. This information helps us keep our Platforms fresh and interesting to our visitors and allows us to tailor content to a visitor’s interests and to identify and fix technical issues with the Platforms.

Device Identifier. We automatically collect your IP address or other unique identifier (“Device Identifier”) for the Device (computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Platforms, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your interests, and gather broad demographic information for aggregate use.

Cookies; Pixel Tags. The technologies used on the Platforms to collect Usage Information, including Device Identifiers, include but are not limited to: cookies (data files placed on a Device when it is used to visit the Platforms), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed), Software Development Kits (“SDKs”), embedded scripts, and other tracking technologies. Cookies may contain a cookie ID that we and third parties can use to track you and your device across digital properties over time. For example, cookies may be used to associate you with social networking sites like Facebook and Twitter and, to enable interaction between your activities on the Platforms and your activities on such social networking sites. We, or our vendors, may place cookies or similar files on your Device for security purposes, to facilitate site navigation, to perform analytics, personalize your experience while visiting our Platforms (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information), and to personalize advertising to you (by us and our third party partners), such as on social media sites and through other online and offline interactions. A pixel tag may tell your browser to get content from another server or send content to another server or third party.

To learn how you may be able to reduce the number of cookies you receive from us, or delete cookies that have already been installed in your browser’s cookie folder, or prevent tracking activities, please refer to your browser’s tools or help menu or other instructions related to your browser. Because an industry-standard Do-Not-Track protocol has not yet been established, we do not currently honor “Do Not Track” signals sent by browsers. However, you may refuse to accept cookies in order to prevent tracking activities. If you do disable or opt out of receiving cookies, please be aware that some features and services on our Platforms may not work properly because we may not be able to recognize and associate you with your account(s). In addition, the offers of services we provide when you visit us may not be as relevant to you or tailored to your interests.

2. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect about and from you for a variety of purposes such as to respond to your questions and requests for services; provide you with access to certain areas and features of the Platforms such as certain products and services; communicate with you about your requests and activities on the Platforms and, in our discretion, changes to any of our policies; tailor content, advertisements, and offers we serve you; improve the Platforms; comply with license obligations; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent. We may also collect your location based information for the purpose of providing you with certain services.

3. SHARING OF INFORMATION

Except as described in this Online Privacy Notice or in our customer Privacy Notice,  and other privacy notices, we will not provide any of your Personal Information to any third parties without your consent. We may also share your information as disclosed at the time you provide your information. Examples of how we share information include:

Third Parties Providing Services. We may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our partners) such as:

— Licensed Life Insurance Agents with the designation of a Generational Gifting Concept Practitioner, and others who provide insurance products and services to you;
— Nonaffiliated companies in order to perform standard business functions on our behalf including those related to processing transactions you request or authorize, or maintaining your account or policy; service providers that host or operate our Platforms, analyze data, or provide customer service; advertisers (including but not limited to ad platforms and networks, social media platforms, and cookie and other online technology providers that facilitate advertising); sponsors or other third parties that participate in or administer our, surveys or provide marketing or promotional assistance and “powered by” partners or partners in co-branded sites. Your Personal Information may also be used by us or shared with our sponsors, partners, advertisers or other third parties to provide you with product/services information or other offers.

Your Agreement to Have Your Personal Information Shared. In addition to the data sharing described above, while on our Platforms, you may also have the opportunity to opt-in to receive information and/or marketing offers from third parties regarding third party products or services or to otherwise consent to the sharing of your information with a third party. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.

Business Transfers. We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.

Legal Disclosure. We may transfer and disclose your information to law enforcement, government agencies, and other third parties to comply with a legal obligation; or when we believe in good faith that the law or a governmental authority requires such disclosure; to verify or enforce our Terms of Use or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to our Platforms or the public.

Aggregate Data: We may share aggregate data with third parties.

4. INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive information about you from third parties through your interactions with our affiliated companies; from data brokers; and from lead generation or referral partners. In addition, if you are on another website and you opt-in to receive information from us, that website will submit to us your email address and other information about you so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook (Meta) or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect (or the third party to share) information about you, including Usage Information and Personal Information such as lists of your friends, “likes”, comments you have shared, groups and location. Third parties (such as social media companies) may also give you the option to post information about your activities on our Platform to your profile page to share with others within your network. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections’” web page, profile page, or similar page on a social networking or other third party website or interactive service. We may supplement the information we collect about you through the Platforms with such information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to engage with products or services that we believe may be of interest to you.

5. YOUR PRIVACY RIGHTS, CHOICE AND ACCESS

You control the Personal Information that you provide to us on the Platforms, but some Personal Information is required by us in order for you to obtain services from us or for you to use the Platforms. If you choose not to provide us with your Personal Information on the Platforms, you may not be able to take advantage of some of the services we offer or use some functionality on the Platforms. Except as provided above in section 3, we will not share Personal Information collected on the Platforms with third parties without your consent. You may also direct us to stop sending you promotional emails by following the removal instructions in a communication you receive from us. Your opt-out request will be processed within 10 business days of the date on which we receive it.

If you wish to modify, verify, correct, or delete any of your Personal Information collected through the Platforms, you may edit your registered user information. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always be possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as your account is active or as needed to provide you services. If you wish to cancel your online account or request that we no longer use your information to provide you services through the platform, contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook (Meta) and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.

6. ADVERTISING; HOW TO OPT-OUT

We may use third party ad network providers to help present ads on the Platforms, as well as other service providers to evaluate and provide us with information about the use of the Platforms and viewing of our content. We do not share Personal Information with these providers (except as described in Section 3 above or in other circumstances with your permission). Such providers may place and access cookies, pixel tags, or similar technologies on your Device to serve you ads or other content personalized to your interests which they infer from your browsing on the Platforms and other sites you have visited. In doing so, the provider collects or has access to information about you and your device, such as your Usage Information. The use of cookies, pixel tags, or similar technologies by these providers is subject to their own privacy policies, not ours.

7. CHILDREN

The Platforms are not directed to children under 16. We do not knowingly collect, use or disclose personally identifiable information from anyone under 16 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 16, we will make reasonable efforts to delete such information from our records.

8. SECURITY OF YOUR INFORMATION

We take information security seriously and use certain reasonable security measures to help protect your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.

9. OTHER SITES

The Platforms may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).

The Platforms may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Online Privacy Notice.

10. CHANGES

We may update this Online Privacy Notice to reflect changes to our information practices. If we make any material retroactive changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Platforms prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

11. CONTACT US

If you have any questions or concerns about this Online Privacy Notice, the practices of the Platforms, or your experiences with the Platforms, please contact us at Info@Generationalgifting.com subject line: Online Privacy Notice Inquiry

How We Protect Your Information

Cyber security is incorporated into our business practices upfront. The Generational Gifting Concept Platform continuously invests in an Enterprise Cyber Security Program consisting of written Information Technology Policies and Standards that are designed to safeguard the security, confidentiality, integrity, and availability of personal information in accordance with applicable laws and regulations. These measures were developed in accordance with leading industry guidelines and best practices. Our Program and our Standards provide a framework for managing risks associated with Generational Gifting Concept Platform’s information technology resources and mechanisms to identify, assess, and monitor risks to nonpublic personal information. The Generational Gifting Concept Platform takes cyber security seriously and we’ll continue to make investments that help protect both customer and employee information. This includes providing the right personnel and resources to our dedicated Information Risk Management Program that is aligned with leading industry guidelines.

Privacy Rights Request 

Certain states have regulations that allow you to request additional privacy rights such as California. If you reside in one of these states and would like to submit a rights request, you can do so by emailing Info@generationalgifting.com subject line : Rights request 

Responsible Disclosure Policy

“Generational Gifting Inc”, “Generational Gifting Concept”,” “We,” “Our,” or “Us,”) is committed to protecting the confidentiality, integrity, and availability of our information systems and applications. We take cybersecurity seriously and encourage those who have discovered possible security issues in our information systems and applications to disclose it to us in a responsible manner. Our Responsible Disclosure Policy (“RDP”) is intended to give security researchers a mechanism to report security issues in any of our information systems and applications.

Generational Gifting Concept Platform RDP Rules:

• Please provide detailed reports with reproducible steps. If the report is not detailed enough to reproduce the issue, the issue may not be marked as triaged.
• Submit one vulnerability per report, unless you need to chain vulnerabilities to provide impact.
• When duplicates occur, only the first report that was received will be triaged (provided that it can be fully reproduced).
• Multiple vulnerabilities caused by one underlying issue will be treated as one valid report.
• Social engineering (e.g., phishing, vishing, smishing) is prohibited.
• Do not access, copy, store, transfer, or download any proprietary or confidential Generational Gifting Concept Platform data.
• Do not delete or alter user generated data; impair, disrupt, or disable information systems and applications; or render data inaccessible.
• Do not engage in any activity that violates any applicable law or regulation. (a) federal or state laws or regulations or (b) the laws or regulations of any country where (i) data, assets or systems reside, (ii) data traffic is routed or (iii) the researcher is conducting research activity.
• Failure to abide by the Generational Gifting Concept Platform’s terms and conditions will be deemed by Generational Gifting Concept Platform, in its sole discretion, to be unauthorized activity. The Generational Gifting Concept Platform expressly reserves all rights afforded to it, by law or in equity, in this regard.

You can report a security issue by emailing Info@GenerationalGifting.com Subject Line : Security Issue

Generational Gifting Concept Platforms Commitment to Protecting Your Data

Restricting Information Access

Access to systems containing personal information is restricted to employees with a legitimate business need to access such information. Service providers are contractually bound to implement and maintain our requirements for the protection of your personal information. They are also required to comply with legal and regulatory requirements related to data privacy and information security.

Information Security Platform & Infrastructure

All external connections to company networks, applications, or data over the public Internet require multi-factor authentication are required to go through a multi-tiered “firewalled” demilitarized zone and a virtual private network (VPN) client. Our antivirus technology infrastructure and content controls are maintained to address the introduction of malicious code at the gateway, server, and client levels, using multiple technologies to diminish the risk relating to new viruses and prevent inappropriate communications, or leakage of personal or confidential information.

Testing and Assessing Risk

The program is subject to reasonable monitoring, review, and adjustment due to the dynamic nature of technology and emerging and evolving security risks and threats, including reasonably foreseeable threats or hazards to the security, confidentiality, and integrity of confidential or restricted information, including personal information. We align our resources to address the most significant risk as threats change.

Regular Monitoring, Evaluation, and Adjustment

We continuously monitor, review, and adjust our cyber security policies and procedures based on changes in technology and sensitivity of information to ensure that we are operating in a manner reasonably designed to protect against reasonably foreseeable threats or hazards to the confidentiality, security, or integrity of personal information. An Incident Response Team exists to investigate and manage potential information security incidents.

Protecting Generational Gifting Concept Platform Systems

Data centers, operations centers, and other key buildings and assets are subject to physical, technical, and administrative security measures and related monitoring. Multiple Internet points of presence are also geographically dispersed to facilitate availability and mitigate the risk of catastrophic events.

Cyber Security Awareness

Employees are our best defense against cyber-attacks. That’s why our cyber security education for employees includes focused communications, events, and training to reinforce the requirement that employees adhere to the Generational Gifting Concept Platform Information Technology Policies and Standards, which are required to be acknowledged annually.

California Consumer Privacy Act Disclosures

Last Updated On: December 13, 2024

This page describes how “Generational Gifting Inc”, “Generational Gifting Concept”, “we”, “us”, or “our”): and its subsidiaries and affiliates that are subject to the California Consumer Privacy Act (“CCPA”) handles Personal Information that is subject to the CCPA for the below types of California residents.

Our systems may contain links to other sites that we do not own or operate and where those sites’ privacy policy may apply.

As used in these Disclosures, “Personal Information” means any information that identifies, describes, or can reasonably be associated with a particular individual.

You may exercise a Right to Know, Right to Delete, Right to Correct, and Right to Limit Sensitive Personal Information Processing by emailing Info@Generationalgifting.com Subject line : Exercise a Right to Know, Delete, Correct, or Limit Sensitive Personal Information

To exercise your preferences and learn about the Right to Opt-Out of Sale/Sharing, review our Preference segment. To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

CALIFORNIA CONSUMER PRIVACY ACT 

Under the California Consumer Privacy Act (“CCPA”), California consumers have the option to ask us not to sell or share their personal information (“Opt Out”). We support your right to Opt Out.

The Generational Gifting Concept platform collects information about you, your device, and how you interact with our websites, social media accounts, online advertisements, mobile applications, and communications in several ways, including using cookies, ReCaptcha and other online tracking technologies. Although we do not “sell” this information for money, we engage in routine online activities and disclose information to third parties in ways that could constitute a “sale” or “sharing” as defined under the CCPA. Please note that the opt-out of “selling” or “sharing” information is based on CCPA requirements and does not incorporate the “selling” or “sharing” regulations of other jurisdictions.

We provide two ways to Opt Out:

Method 1: If you provide your email address, we will identify matching information within our systems and we will no longer sell or share such information for targeted advertising purposes, unless you opt back in. In addition, you will have the opportunity to block cookie and other tracking technologies deployed on our sites that sell or share your personal information for targeted advertising purposes (“Adtech”), on your current browser (e.g., the browser you are using at the time of the entry). We will only use your email to process and store your Opt Out request, and for no other purpose.

Method 2: You may also anonymously Opt Out of Adtech ONLY, on your current browser, without providing an email address. If you choose this option, we will not be able to match your email address with our internal systems to stop the sale or sharing of your email address and associated information as defined in the CCPA, if any.

To support our different brand relationships, The Generational Gifting Concept Platform applies preferences by brand. You must Opt Out separately for each internet browser, and each Generational Gifting Concept Platform. 

California Consumer Privacy Disclosure: Individuals and Website Visitors

Last Updated On: December 13, 2024

The Generational Gifting Concept Platform provides this Privacy Disclosure (“Disclosure”) to inform you how we process Personal Information that we collect through our websites, social media accounts, online advertisements, and online communications (collectively, our “Platforms”), through communications (such as mail or phone), at in-person meetings and events, and through other online and offline methods.

Changes: We may update this Disclosure from time to time. Any updated Disclosure will be effective when posted. Please check this Disclosure periodically for updates. If required by law, we will contact you directly to provide you with an updated Disclosure.

1. Sources of Personal Information

We collect Personal Information about you from the following sources:

A. Directly from you. We may collect Personal Information you provide to us directly, such as when you contact us through our Platforms, interact with us in person, sign up for offers or newsletters, or otherwise communicate with us.

B. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Platforms. This may include information about how you use and interact with our Platforms or otherwise interact with us, information about your device, and internet usage information. For more information, see “Section 5 – Cookies and Other Tracking Technologies.”

C. From service providers who collect information on our behalf.

D. From our affiliates and subsidiaries.

E. From Generational Gifting Concept Practitioners (Licensed Life Insurance Agents).

F. From third parties, such as commercial business partners, data brokers, social media companies or other independent parties who interact with us.

G. From publicly available sources. We may collect Personal Information about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Disclosure, including third party sources, and use or disclose it for the purposes identified below.

2. Types of Personal Information We Collect

We may collect the following types of Personal Information about you:

A. Identifiers, such as your name, email address, physical address, telephone number, and device identifiers or any other personal information you have provided to us.

B. Protected class and demographic information, such as age.

C. Internet or other electronic network activity information, about you, your device, and how you interact with the Platforms. Data elements may include browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), operating system, browser used, and other information about how you interact with our Platforms (such as pages on our Platforms that you have viewed).

D. Non-precise geolocation data, such as your location as derived from your IP address.

3. How We Use Personal Information

We may use Personal Information for the following purposes:

A. For our internal business purposes, such as operating our Platforms and customizing the content; maintaining internal business records, such as accounting, document management and other similar activities; enforcing our policies and rules; management reporting; auditing; IT administration of our network, intranet, and other technologies; and IT security management and tasks.

B. For our internal research and business improvement purposes, such as verifying, maintaining, or improving the quality of our business (including our Platforms); evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.

C. For legal, safety, or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against the Company, its personnel, and its customers; for the establishment, exercise or defense of legal claims; protecting Company, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.

D. In connection with a corporate transaction, such as if we acquire, sell or transfer all or a portion of our business or assets.

E. For marketing and targeted advertising, such as marketing our business or that of our affiliates, business partners, or other third parties (for purposes of this paragraph alone, “we” or ”our” includes our affiliates, business partners, or other third parties we may be working with to provide marketing). For example, we may use Personal Information we collect to personalize advertising to you on our Platforms or third party sites and digital properties; to analyze interactions with our email communications or website areas viewed; to develop product, brand or services audiences (including by identifying you across devices/sites) to better target our advertising to you; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email or by contacting us using the information in the Contact Information section below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Information

We may disclose Personal Information to third parties, including the categories of recipients described below. Although we do not “sell” Personal Information for money, we engage in routine practices involving third parties that could be considered a “sale” (meaning a disclosure of Personal Information to a third party for consideration) or “sharing” (meaning a disclosure of Personal Information to a third party for targeted advertising purposes), as defined under the CCPA. We do not knowingly sell or share Personal Information about minors.

Categories of personal information we collect

Identifiers such as your name, email address, physical address, telephone number, and device identifiers, Internet or other electronic network activity about you, your device, and how you interact with the Platforms. Data elements may include browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), operating system, browser used, and other information about how you interact with our Platforms (such as pages on our Platforms that you have viewed)., Non-precise geolocation data, such as your location as derived from your IP address,  Protected class and demographic information under California or federal law such as age (including birthdates), gender, and veteran status. Inferences drawn from any of the information we collect about your preferences or behavior.

Categories of personal information we Do not collect

Records about you such as covered medical or health information, investments, estimated income, and other information that we obtain from commercial data partners., Commercial information  such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies., Audio, visual, or other sensory information such as photographs and audio/video recordings., Professional or employment-related information such as job title, organization and other professional information, Education information, , Sensitive Personal Information such as health information obtained from commercial data partners or inferred from your interactions with our Platforms.

CATEGORIES OF THIRD PARTIES WITH WHOM WE DISCLOSE PERSONAL INFORMATION FOR A BUSINESS PURPOSE

• Affiliates and subsidiaries
• Professional consultants
• Vendors necessary to complete transactions you request
• Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
• Other entities in connection with a corporate transaction
• Entities to which you have consented to the disclosure

The categories of recipients in the reference above are used to mean:

A. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.

B. Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.

C. Vendors necessary to complete a transaction that you request, such as shipping companies.

D. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with laws or legal requirements, to enforce or apply our Terms of Use, Terms of Service and other agreements or policies and to protect Company, our customers’, or third parties’ safety, property, or rights.

E. Other entities in connection with a corporate transaction, such as if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.

F. Entities to which you have consented to the disclosure.

Categories of third parties to whom personal information is sold* or shared*Advertisers, ad platforms and networks, and social media platforms, Third parties whose cookies and tracking tools we use as described above (Cookies and Tracking Technologies) Commercial data partners to whom we make information available for their own marketing purposes, Partners who work with us on promotional or sponsorship opportunities, including co-branded products and services

5. Cookies and Other Tracking Technologies

Our Platforms (and authorized third parties) use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Platforms. This section contains additional information about:

• The types of tracking technologies we use and the purposes for which we use them
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

A. Types of cookies and tracking technologies we use

Our Platforms and the third parties that we authorize may use the following tracking technologies:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
• Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier. In addition to the uses described in Section 5.B below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
• Session replay tools, which record your interactions with our Platforms, such as how you move throughout our Platforms and engage with our webforms. In addition to the uses described in Section 5.B below, this information helps us improve our Platforms and identify and fix technical issues visitors may be having with our Platforms.

Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences, some of which may be developed by a third party.

B. Purposes for Using These Technologies

We and authorized third parties use these technologies for purposes including:

• Personalization, such as remembering user preferences, login details and browsing behavior; tracking your activity across online properties and Platforms over time to better understand your preferences and interests; and personalizing your online content;
• Improving performance, such as maintaining and improving the performance of our Platforms;
• Analytics, such as analyzing how our Platforms are used. For example, we use Google Analytics to help us improve our Platforms, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners; and
• Advertising, such as providing you with offers that may be of interest to you; conducting targeted advertising to you on our Platforms and those of third parties; and measuring the effectiveness of our communications with you and advertising campaigns, including identifying how and when you engage with our communications.

C. Personal Information Collected

These tracking technologies collect data about you and your device, such as your IP address, cookie ID, device ID, AdID, operating system, browser used, browser history, search history, and information about how you interact with our Platforms (such as pages on our Platforms that you have viewed, including your specific mouse movements, page clicks, and other session replay information).

D. Disclosures of Personal Information

We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Platforms such as social media companies, advertising networks, companies that facilitate session replay recordings and analysis, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Platforms.

E. Your Choices

Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Platforms’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our practitioners or representatives.

Some browsers have incorporated Do Not Track (“DNT”) preferences. We do not currently honor such signals.

6. Data Retention

Our Information Governance and Records Management Program establishes and maintains company policies and procedures governing the creation, retention, storage, and disposition of corporate records and information, provided that such information to be deleted or destroyed is not subject to regulatory requirement to retain it or a legal hold. We retain corporate records for the minimum time period required by law or regulation and/or for a longer period of time consistent with business needs. We determine retention periods for corporate record information using both legal/regulatory citations and business requirements. Citations for retention periods are regularly reviewed by outside counsel and updated as necessary. CCPA rights request records are subject to a two year retention period as required by California law.

7. Data Subject Rights

California Consumers may have certain rights, subject to legal limitations, regarding the collection, use, and sharing of Personal Information under the CCPA, such as:

• Right to Know. You may request information about the categories of Personal Information we have collected about you; the categories of sources from which we collected the Personal Information; the purposes for collecting, selling, or sharing the Personal Information; and to whom we have disclosed your Personal Information and why. You may also request the specific pieces of Personal Information we have collected about you.
• Right to Delete. You may request that we delete Personal Information that we have collected from you.
• Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.
• Right to Limit Sensitive Personal Information Processing. We generally only use Sensitive Personal Information that is subject to the CCPA for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you. In limited circumstances, you may have the right to limit our processing of your Sensitive Personal Information.
• Right to Opt Out of Sale/Sharing. You may request to opt out from the sale or sharing of your Personal Information. We do not knowingly sell or share any Personal Information of minors under the age of 16.

You may exercise a Right to Know, Right to Delete, Right to Correct, and Right to Limit Sensitive Personal Information Processing by emailing Info@Generationalgifting.com Subject  “Exercise a Right to Know, Delete, Correct, or Limit Sensitive Personal Information

To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights.

Verification: In order to process requests, we may need to obtain information to locate you in our records or verify your identity using reasonable methods. For Right to Know, Right to Delete, Right to Correct, and Right to Limit Processing of Sensitive Personal Information, we will collect some or all of the following data elements: Name, Date of Birth, Email, Phone Number, and Address. We use a third party identity verification and fraud prevention service to verify the information you provide on your rights request form and which may present you with additional knowledge-based questions. When it comes to identity verification, our third party only tells us whether your identity passes verification and we do not use this information for any other purpose. In some cases, we may ask for more or different information if needed to otherwise support you request such as in cases of authorized agents. To exercise the Right to Opt Out of Sale/Sharing, you may be asked to provide and verify your email address.

Authorized Agents: Authorized agents may exercise rights on behalf of consumers by submitting a rights request to Info@Generationalgifting.com and indicating that they are submitting the request as an agent. Agents should provide their own information to verify the agent’s identity, after which we will contact the agent with additional instructions to complete the consumer right submission process. We may require agents to demonstrate authority to act on behalf of a consumer by providing signed permission and may require consumers to directly verify their identity with us using the methods described above.

Timing: We will respond to Right to Know, Right to Delete, and Right to Correct requests within 45 days, unless we need more time, in which case, we will notify you and may take up to 90 days total to respond to your request. We will respond to Right to Limit Sensitive Personal Information Processing and Right to Opt Out of Sale/Sharing requests within 15 days.