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Our Privacy Policy

Last Updated: Dec 7, 2023

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Privacy Policy

Please take a moment to familiarize yourself with our privacy practices and contact moc.worrub@ycavirp if you have any questions.

This Privacy Policy applies to https://burrow.com/ (the “Site”) and all other websites owned and operated by Burrow Inc. The term “Burrow,” “we,” and “us” includes Burrow Inc. and our affiliates and subsidiaries.

The Privacy Policy explains how Burrow may:

  • collect,
  • use, and
  • disclose

Personal Information (defined below) we obtain through the Site, your communications with us, or from third parties. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. “Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized such that it does not allow a third party to easily identify a specific individual.

THE SITE COLLECTS YOUR INFORMATION

We collect Personal Information when you choose to provide it to us including when you:

  • register to use the Site;
  • purchase a Burrow Product on the Site;
  • use the Site; and
  • communicate with us.

We also collect Personal Information by using cookies, pixels, server logs, and other similar technology as you use the Site. Please note that we may use third party service providers to help operate the Site and these third party service providers may collect Personal Information from our Site as well.

Register an Account. The Site gives you the option of creating a user account (an “Account”). If you decide to create an Account, you will provide us with certain Personal Information, such as user name, password, name or alias, email address. You are not required to register to use the Site.

Purchase a Burrow Product. When you purchase a Burrow product using the Site, you are given the option of logging into an Account or checking out as a guest. In either case, when you purchase a Burrow product, you will provide us with Personal Information, such as your name, email address, telephone number, billing address and shipping address. We also collect your purchase history.

Make a Payment. When you make a payment through the Site, you may need to provide Personal Information to our third party payment processors. Such Personal Information may include sensitive Personal Information, such as your credit card number.

Submit Information to the Site. We collect information you submit to the Site. For example, when you post a review of a Burrow product on the Site or refer a friend to Burrow using the Site, the Site will collect the information in your submission to the Site, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.

When you provide us with your email address or phone number, we make certain inferences about you that may be considered protected class information. We may make inferences about age, sex, income level, geo-location, familiy status, and political affiliation by leveraging data analytics service providers that provide us with the inferences. The inferences are not based on actual personal information and may be inaccurate.

Additionally, we may collect on-site behavioral data such as purchasing tendencies, browsing behavior and considered purchases.

Communicate with Us. We may also collect Personal Information from you when you communicate with us. For example, you may send us Personal Information by writing an email to us, subscribing to the Burrow newsletter, or making a reservation for an event hosted by Burrow. If you contact us, we may keep a record of that correspondence.

Take a Survey. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. For example, you may be asked to provide contact information as well as information about your height, weight, gender or date of birth.

Information You Provide About a Third Party. If you choose to use any Burrow referral service to tell a friend about Burrow, we may collect your friend's Personal Information, such as name and email address. We will automatically send your friend a one-time email inviting him or her to purchase a Burrow product. We store your friend’s information in order to send this one-time email and to track the success of our referral program.

Passive Collection. The Site collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We use this data to analyze trends in the aggregate and administer the site. Non-personal information that we passively collect may be combined with other information about you, including Personal Information.

Tracking Technologies. Burrow and its partners use cookies, pixels, server logs, and other similar technology to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. Non-personal information that we collect using these technologies may be combined with other information about you, including Personal Information.

Information Provided by Third Parties. Burrow may collect information about you from third parties or supplement the information we collect from you with additional records received from third parties. Information is collected from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you.

HOW BURROW USES YOUR INFORMATION

We use Personal Information to facilitate and improve our services, and communicate with you.

Internal and Service-Related Usage. We use and retain information, including Personal Information, to improve and facilitate the Site and our services. We may also use such data to help us deliver targeted advertising to consumers that is displayed on both Burrow websites and unaffiliated websites, to analyze interactions with and performance of our Site, to measure the effectiveness of advertising on behalf of our advertising partners, and to identify the audience most likely to respond to an advertisement. We may also use data from third parties (such as data vendors) pursuant to their own privacy policies, and enhance information (including Personal Information) that we have collected with such third-party data. We believe that the use of such information is helpful to providing users with better services. However, if you would like to opt-out of these interest-based advertisements, please follow the opt-out process described below under “Choice.”

Communications. We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.

SMS. You may elect to receive text messages from us. When you sign up to receive text messages, we will send you information about promotional offers and more. To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages. For more information about text messages, see our Terms and Conditions.

Marketing. We may use information about you, including Personal Information, to send you information about Burrow’s products and services.

Non-Personal Information. We may use anonymized, aggregated or other data that is not Personal Information for any purpose, including marketing. These uses may include but are not limited to analyzing interactions with and performance of the Site, enabling us to improve our Site and services, and sharing such information with our business partners, affiliates, or any other third party. Similarly, we may enhance any such anonymized and aggregated data collected via our Site with other information collected from our business partners.

BURROW MAY DISCLOSE YOUR INFORMATION

We may share your information:

  • to comply with legal obligations;
  • to protect and defend our rights and property; and
  • with your permission.

Your information may be shared with third parties for our marketing purposes. We may share the following personal information with third party ad networks - IP Address, internet or electronic activity, purchasing tendencies, considered purchases, purchase history and possibly other unique online identifiers. We may also share your email, and telephone with a third party for behavioral on-site targeting and email and/or text marketing for Burrow products. If you would like to opt out of this sharing email oc.dnikrednuw@stseuqerycavirp and follow the directions here.

We use third parties to improve our ability to identify visitors to our website. As part of this service, we may make available identifiers to these third parties including our visitors’ IP addresses, cookies, and hashed versions of email addresses captured from your visit. We, and third parties, use this data to obtain more information about our visitors and reach out to them through other channels, such as email and/or direct mail. You have the right to opt-out of this activity.

We use service Providers. We may share Personal Information with our service providers who perform services on our behalf. These service providers are authorized to use your Personal Information only as necessary to provide these services to us.

  • Providing customer services including fulfilling orders, delivering packages, and communicating with you about your order
  • Payment processing
  • Sending, evaluating and improving marketing communications
  • Selling and marketing our products
  • Fulfilling subscription services
  • Conducting research and analysis
  • Measuring and improving the performance of the Site
  • Verifying your identity and preventing fraud
  • Developing and improving Burrow products and services
  • Registering your Account
  • Detecting, preventing and remediating fraud or other potentially prohibited or illegal activities *Displaying to Other Users.*The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order, government request, or subpoena. We may also access, preserve, and disclose your Personal Information, other account information, and content if we believe in good faith that disclosure is necessary to protect yours’, ours’ or others’ rights, property, or safety, or investigate fraud.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your Personal Information following any of the foregoing events should be governed by the provisions of the Privacy Policy in effect at the time such Personal Information was collected. We may also disclose your Personal Information with your permission.

ACCESS

Upon request Burrow will provide you with information about whether we hold any of your Personal Information. If you would like to access, update, correct, or delete any information that you have provided to us through your use of the Site, you may contact us at moc.worrub@troppus. We will respond to your request within a reasonable timeframe. We reserve the right to save transaction data as is necessary to comply with legal obligations or for purposes of standard business operations.

CHOICE

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

To manage our advertising on other sites, we engage third party advertising partners. These third party partners may use technologies such as cookies to gather information about your activities on the Site and other sites in order to provide you advertising based upon your browsing activities and interests. Certain of our third party advertising partners participate in self-regulatory organizations, and those organizations operate websites that give you the ability to opt-out of receiving targeted ads from those partners. You can access these websites, and also learn more about targeted advertising and privacy, at Network Advertising or AboutAds. You can also choose not to be included in Google Analytics here.

To be clear, whether you are opting out by adjusting your browser/device settings or by using a website established by a self-regulatory group, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information in accordance with this policy. If you would like to opt-out of Burrow sharing your information with third parties (such as data vendors) for non-Burrow related marketing purposes, send an email to moc.worrub@troppus with the word “privacy” in the subject of the email.

THIRD PARTY SITES AND SOCIAL MEDIA PLATFORMS

The Site may contain links to other websites and other websites may reference or link to our Site. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

The Site also contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

SECURITY OF YOUR INFORMATION

We take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We follow generally accepted standards to protect Personal Information submitted to us, both during transmission and once it is received. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please email us at moc.worrub@troppus with the word “privacy” in the subject of the email. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no part of the Site is directed to children under the age of 16. If you learn that your child has provided us with Personal Information without your consent, you may alert us at moc.worrub@troppus. If we learn that we have collected any Personal Information from children under 16, we will promptly take steps to delete such information and terminate the child’s account.

INTERNATIONAL USERS

By using the Site, you will transfer data to the United States. By choosing to visit the Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the State of New York and the adjudication of any disputes arising in connection with Burrow or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

EU-U.S. PRIVACY SHIELD

Burrow Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Burrow Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. Under the Privacy Shield Framework, Burrow, Inc. is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. Burrow, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Burrow Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Burrow, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

POST A QUESTION OR SUGGESTION

If you have suggestions for improving this Privacy Policy, please send an e-mail to moc.worrub@troppus with the word “privacy” in the subject of the email.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may revise this Privacy Policy, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Contact Information

Burrow, Inc. 15 West 27th Street, 9th Floor, New York, NY 10001 Email: moc.worrub@ycavirp and include the word “privacy” in the subject of the email

Privacy Policy for Canadian Users

Last updated: 10/11/22

Please take a moment to familiarize yourself with our privacy practices and contact moc.worrub@ycavirp if you have any questions.

INTRODUCTION

Burrow Inc. and our affiliates and subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

·       How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).

·       Describes the types of information we may collect from you or that you may provide when you visit the website www.burrow.com/en-ca / (our “Website”).

·       Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. 

This policy applies to information we collect, use, or disclose about you:

·       On this Website.

·       In email, text, and other electronic messages between you and this Website.

·       When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

·       When you participate in a contest/questionnaire/survey.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

This policy DOES NOT apply to information that:

·       We collect offline or through any other means, including on any other Company or third-party website (including our affiliates and subsidiaries).

·       You provide to or is collected by any third party (including our affiliates and subsidiaries), through any application or content (including advertising) that may link to or be accessible from or on the Website.

·       Is used for the purposes of processing your order through delivery services such as UPS, FedEx, Canada Post etc.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. 

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

·       Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (“personal information”). 

·       Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature. 

·       Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.

·       Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

·       Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise. 

·       User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.

·       Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

·       Third parties or publicly available sources, for example, our business partners.

Information You Provide to Us 

The information we collect directly from you on or through our Website may include:

·       Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, purchasing goods or communicating with us. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

·       Records and copies of your correspondence (including email addresses), if you contact us.

·       Your responses to surveys that we might ask you to complete for research purposes.

·       Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

·       Your search queries on the Website.

You may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies  

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·       Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

·       Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool or https://privacy.burrow.com/opt-out for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data and does not include personal information, and we maintain it or associate it with personal information we collect in other ways, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

·       Estimate our audience size and usage patterns.

·       Store information about your preferences, allowing us to customize our Website according to your individual interests.

·       Speed up your searches.

·       Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

·       Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 

·       Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

·       Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. 

You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

·       To present our Website and its contents to you.

·       To provide you with information, products, or services that you request from us.

·       To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.

·       To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.

·       To notify you about changes to our Website or any products or services we offer or provide though it.

·       To improve our Website, products or services, marketing, or customer relationships and experiences.

·       To allow you to participate in interactive features, social media, or similar features on our Website.

·       To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

·       In any other way we may describe when you provide the information.

·       For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form), adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us support.canada@burrow.com . For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

·       To our subsidiaries and affiliates.

·       In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Burrow Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Burrow Inc. about our customers and users is among the assets transferred.

·       To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers' advertisement to that target audience.

·       To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.

·       To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

·       To fulfill the purpose for which you provide it. 

·       For any other purpose disclosed by us when you provide the information.

·       With your consent.

We may also disclose your personal information:

·       To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.

·       To enforce or apply our terms of use (https://burrow.com/terms) and other agreements, including for billing and collection purposes.

·       If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Burrow Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

·       Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.

·       Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your data (registration form. You can also opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to support.canada@burrow.com.

·       Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form)/ or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to support.canada@burrow.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.

·       Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by visiting Digital Advertising Alliance of Canada Opt-Out Tool or https://privacy.burrow.com/opt-out. For this opt-out mechanism to function, you must have your browser set to accept browser cookies. 

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. 

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. 

CHILDREN UNDER THE AGE OF 13

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [support.canada@burrow.com].

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Website and visiting your account page. 

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at [support.canada@burrow.com] to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

·       Information protected by solicitor-client privilege.

·       Information that is part of a formal dispute resolution process.

·       Information that is about another individual that would reveal their personal information or confidential commercial information.

·       Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer/ Kabeer Chopra at kabeer.chopra@burrow.com.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use [https://burrow.com/terms].

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support.canada@burrow.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. 

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. 

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: 

Privacy Officer/ Kabeer Chopra

Burrow, Inc. 15 West 27th Street, 9th Floor, New York, NY 10001 

Email: support.canada@burrow.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

4883-4750-8280 v1 [101089-1]

Burrow Text Messaging Terms & Conditions

If subscribed, you agree to receive recurring automated promotional and personalized marketing text (e.g., SMS and MMS) messages (e.g. cart reminders) from Burrow, including text messages that may be sent using an automatic telephone dialing system, to the mobile telephone number you provided when signing up or any other number that you designate. Consent to receive automated marketing text messages is not a condition of any purchase. Msg & Data rates may apply. 

Message frequency will vary. Burrow reserves the right to alter the frequency of messages sent at any time, so as to increase or decrease the total number of sent messages. Burrow also reserves the right to change the short code or phone number from which messages are sent and we will notify you when we do so. 

Not all mobile devices or handsets may be supported and our messages may not be deliverable in all areas. Burrow, its service providers and the mobile carriers supported by the program are not liable for delayed or undelivered messages. 

You also agree to our Burrow Terms of Use and Burrow Privacy Policy (above). 

We are able to deliver messages to the following mobile phone carriers: Major carriers: AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Alltel, Boost Mobile, Nextel, and Virgin Mobile. Minor carriers: Alaska Communications Systems (ACS), Appalachian Wireless (EKN), Bluegrass Cellular, Cellular One of East Central IL (ECIT), Cellular One of Northeast Pennsylvania, Cincinnati Bell Wireless, Cricket, Coral Wireless (Mobi PCS), COX, Cross, Element Mobile (Flat Wireless), Epic Touch (Elkhart Telephone), GCI, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri), Illinois Valley Cellular, Inland Cellular, iWireless (Iowa Wireless), Keystone Wireless (Immix Wireless/PC Man), Mosaic (Consolidated or CTC Telecom), Nex-Tech Wireless, NTelos, Panhandle Communications, Pioneer, Plateau (Texas RSA 3 Ltd), Revol, RINA, Simmetry (TMP Corporation), Thumb Cellular, Union Wireless, United Wireless, Viaero Wireless, and West Central (WCC or 5 Star Wireless). 

Cancellation

Text the keyword STOP, END, CANCEL, UNSUBSCRIBE or QUIT to our shortcode to cancel. After texting STOP, END, CANCEL, UNSUBSCRIBE or QUIT to our shortcode you will receive one additional message confirming that your request has been processed. You acknowledge that our text message platform may not recognize and respond to unsubscribe requests that do not include the STOP, END, CANCEL, UNSUBSCRIBE or QUIT keyword commands and agree that Burrow and its service providers will have no liability for failing to honor such requests. If you unsubscribe from one of our text message programs, you may continue to receive text messages from Burrow through any other programs you have joined until you separately unsubscribe from those programs. 

Help

Text the keyword HELP to our shortcode to return customer care contact information.

Customer Care

If you are experiencing any problems, please email support@burrow.com. 

Contact

This message program is a service of Burrow, located at 15 W 27th St Fl 10, New York City, New York 10001. 

Dispute Resolution

  1. General. In the interest of resolving disputes between you and Burrow in the most expedient and cost effective manner, you and Burrow agree that any dispute arising out of or in any way related to these messaging terms and conditions ("Messaging Terms") or your receipt of text messages from Burrow or its service providers will be resolved by binding arbitration. Arbitration is less formal than a lawsuit in court. Arbitration uses a neutral arbitrator instead of a judge or jury, may allow for more limited discovery than in court, and can be subject to very limited review by courts. Arbitrators can award the same damages and relief that a court can award. This agreement to arbitrate disputes includes all claims arising out of or in any way related to these Messaging Terms, or your receipt of text messages from Burrow or its service providers whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory, and regardless of when a claim arises. YOU UNDERSTAND AND AGREE THAT, BY AGREEING TO THESE MESSAGING TERMS, YOU AND Burrow ARE EACH WAIVING THE RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION AND THAT THESE MESSAGING TERMS SHALL BE SUBJECT TO AND GOVERNED BY THE FEDERAL ARBITRATION ACT. 
  2. Exceptions. Notwithstanding subsection (a) above, nothing in these Messaging Terms will be deemed to waive, preclude, or otherwise limit the right of you or Burrow to: (i) bring an individual action in small claims court; (ii) pursue an enforcement action through the applicable federal, state, or local agency if that action is available; (iii) seek injunctive relief in aid of arbitration from a court of competent jurisdiction; or (iv) file suit in a court of law to address an intellectual property infringement claim. 
  3. Arbitrator. Any arbitration between you and Burrow will be governed by the Federal Arbitration Act and the Commercial Dispute Resolution Procedures and Supplementary Procedures for Consumer Related Disputes (collectively, "AAA Rules") of the American Arbitration Association ("AAA"), as modified by these Messaging Terms, and will be administered by the AAA. The AAA Rules and filing forms are available online at www.adr.org, by calling the AAA at 1-800-778-7879, or by contacting Burrow. The arbitrator has exclusive authority to resolve any dispute relating to the interpretation, applicability, or enforceability of this binding arbitration agreement. 
  4. Notice; Process. If you or Burrow intends to seek arbitration, then the party seeking arbitration must first send a written notice of the dispute to the other party by U.S. Mail ("Notice"). Burrow address for Notice is: 15 W 27th St Fl 10, New York City, New York 10001, Attn: Chief Executive Officer. The Notice must: (i) describe the nature and basis of the claim or dispute; and (ii) set forth the specific relief sought ("Demand"). You and Burrow will make good faith efforts to resolve the claim directly, but if you and Burrow do not reach an agreement to do so within 30 days after the Notice is received, you or Burrow may commence an arbitration proceeding. During the arbitration, the amount of any settlement offer made by you or Burrow must not be disclosed to the arbitrator until after the arbitrator makes a final decision and award, if any. (e) Fees. If you commence arbitration in accordance with these Messaging Terms, Burrow will reimburse you for your payment of the filing fee, unless your claim is for more than $15,000 or as set forth below, in which case the payment of any fees will be decided by the AAA Rules. If the claim is for $15,000 or less, you may choose whether the arbitration will be conducted: (i) solely on the basis of documents submitted to the arbitrator; (ii) through a non-appearance based telephone hearing; or (iii) by an in-person hearing as established by the AAA Rules. If the arbitrator finds that either the substance of your claim or the relief sought in the Demand is frivolous or brought for an improper purpose (as measured by the standards set forth in Federal Rule of Civil Procedure 11(b)), then the payment of all fees will be governed by the AAA Rules. In that case, you agree to reimburse Burrow for all monies previously disbursed by it that are otherwise your obligation to pay under the AAA Rules. Regardless of the manner in which the arbitration is conducted, the arbitrator must issue a reasoned written decision sufficient to explain the essential findings and conclusions on which the decision and award, if any, are based. You and Burrow agree that such written decision, and information exchanged during arbitration, will be kept confidential except to the extent necessary to enforce or permit limited judicial review of the award. The arbitrator may make rulings and resolve disputes as to the payment and reimbursement of fees or expenses at any time during the proceeding and upon request from you or Burrow made within 14 days of the arbitrator's ruling on the merits. 
  5. No Class Actions. YOU AND Burrow AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. Further, unless both you and Burrow agree otherwise in a signed writing, the arbitrator may not consolidate more than one person's claims, and may not otherwise preside over any form of a representative or class proceeding. 
  6. Modifications to this Arbitration Provision. Notwithstanding anything to the contrary in these Messaging Terms, if Burrow makes any future change to this arbitration provision, other than a change to Burrow address for Notice, you may reject the change by sending us written notice within 30 days of the change to Burrow address for Notice, in which case this arbitration provision, as in effect immediately prior to the changes you rejected, will continue to govern any disputes between you and Burrow. 
  7. Enforceability. If an arbitrator decides that applicable law precludes enforcement of any of the limitations of subsection (f) above (addressing class, representative and consolidated proceedings) as to a particular claim for relief, then that claim (and only that claim) must be severed from the arbitration and brought in court. If any other provision of these Messaging Terms is found to be unenforceable, the applicable provision shall be deemed stricken and the remainder of these Messaging Terms shall remain in full force and effect.

We collect the personal information you provide to us when you subscribe to newsletters and updates via email and/or text. The categories of information we may collect include:

  • Personal Identifiers, including name, email address, postal address, and online Identifiers
  • Internet Activity
  • Commercial Information, including purchases
  • Location Information, including general location data

We collect the personal information you provide to us when you make purchases on burrow.com. The categories of information we may collect include:

  • Personal Identifiers, including name, email address, postal address, telephone number, and online Identifiers
  • Internet Activity
  • Commercial Information, including purchases
  • Financial Information, including credit or debit card number and account security or access credentials
  • Location Information, including general location data
  • Inferences from Other Data, including inferences created from other personal information collected

We collect the personal information you provide to us when you visit burrow.com without necessarily making a purchase. The categories of information we may collect include:

  • Personal Identifiers, including email address and online Identifiers
  • Internet Activity
  • Location Information, including general location data
  • Inferences from Other Data, including inferences created from other personal information collected

Cookie Policy

We use cookies to create a better experience for you on our site. For example, cookies prevent you from having to login repeatedly, and they help us remember items you've added to your cart. We also use third-party cookies, which are cookies placed by third parties for advertising and analytics purposes. You can control these cookies through your browser settings.

Information from other sources

We may collect personal information about you from third-party sources, including Retail Partners.

The categories of information we may collect include:

Retail Partners

  • Personal Identifiers, including Name, Email address, Postal address, and Telephone number
  • Commercial Information, including Purchases

How long we keep your data

We do not retain data for any longer than is necessary for the purposes described in this Policy.

We generally retain data according to the guidelines below.

Type of DataRetention Period
Cookies and online data we collect while you use our website, including Online Identifiers, Internet ActivityWe delete or anonymize data concerning your use of our website within 10 years of collecting it.
Data we collect in order to process and ship orders you place with us, including Name, Email address, Postal address, Telephone number, Purchases, Credit or debit card number, Bank or other financial account numberWe keep personal information related to products and services you purchase for as long as the personal data is required for us to fulfill our contract with you, and for 10 years from your last purchase with us. We may keep data beyond this period in anonymized form.
Data we collect when you contact us for customer support and other inquiries, including Name, Email address, Telephone number, PurchasesWe keep customer feedback and correspondence with our customer service for up to 10 years to help us respond to any questions or complaints. We may keep data beyond this period in anonymized form.
Data we collect when you sign up for promotional and marketing communications, including Name, Email address, Postal address, Telephone number, Online Identifiers, Internet Activity, Purchases, Inferences created from other personal information collectedWhere you have signed up to receive promotional and marketing communications from us, we will retain any data collected until you opt out or request its deletion. We may keep data beyond this period in anonymized form. We will further retain a record of any opt-outs in order to prevent sending you future communications.
Data we collect when you review our products, answer surveys, or send feedback, including Name, Email address, PurchasesWe retain review, survey, and feedback data for up to 10 years following your last contact with us. We may keep data beyond this period in anonymized form to help improve our products and services.
Data we collect in connection with privacy requests, including Name, Email address, Online IdentifiersWe retain records related to privacy requests as long as necessary to comply with our legal obligations.
Data we collect for security purposes, including Name, Email address, Online IdentifiersWe retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures.

Why we process your information

We process personal information for the following business and commercial purposes:

  • Analyzing Data
  • Conducting Surveys
  • Creating Customer Profiles
  • Delivering Targeted Ads
  • Fulfilling Customer Orders
  • Improving our Products & Services
  • Marketing Our Products & Services
  • Meeting Compliance & Legal Requirements
  • Operating Our Website or Mobile Apps
  • Preventing Fraud
  • Processing Payments
  • Providing Customer Support
  • Providing Cybersecurity
  • Sending Promotional Communications
  • Storing and Managing Data

We may disclose personal information about you for business and commercial purposes when you subscribe to newsletters and updates via email and/or text:

Personal Information CategoryCategories of Service ProvidersCategories of Third Parties
Personal IdentifiersCustomer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Website Operations ToolAd Networks and Data Analytics Providers
Internet ActivityCommerce Software Tools, IT Infrastructure Services, and Sales & Marketing ToolsAd Networks and Data Analytics Providers

We may disclose personal information about you for business and commercial purposes when you make purchases on burrow.com:

Personal Information CategoryCategories of Service ProvidersCategories of Third Parties
Personal IdentifiersBusiness Operations Tool, Commerce Software Tools, Communications Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, Sales & Marketing Tools, Shipping Services, and Website Operations ToolAd Networks, Data Analytics Providers, Payment Processors, Product Insurance, and Shipping Services
Internet ActivityCommerce Software Tools, IT Infrastructure Services, and Sales & Marketing ToolsAd Networks and Data Analytics Providers
Commercial InformationBusiness Operations Tool, Commerce Software Tools, Communications Tools, IT Infrastructure Services, Payment Processors, and Sales & Marketing ToolsAd Networks, Data Analytics Providers, Payment Processors, and Product Insurance
Financial InformationBusiness Operations Tool, Commerce Software Tools, Communications Tools, Payment Processors, and Sales & Marketing ToolsNone

We may disclose personal information about you for business and commercial purposes when you visit burrow.com without necessarily making a purchase:

Personal Information CategoryCategories of Service ProvidersCategories of Third Parties
Personal IdentifiersBusiness Operations Tool, Commerce Software Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, Sales & Marketing Tools, Shipping Services, and Website Operations ToolAd Networks, Data Analytics Providers, Payment Processors, Product Insurance, and Shipping Services
Internet ActivityIT Infrastructure Services and Sales & Marketing ToolsAd Networks and Data Analytics Providers

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for their own marketing reasons.