PRIVACY POLICY

Last modified: November 1, 2021

Introduction

Affinity Group (“Company”, “we”, “us”, “our” or “Affinity Group”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy (together with our Terms of Use and any other documents referenced therein or herein) describes the personal information that we collect from you or that you provide on our websites (including mobile websites), applications, through other services that we may offer in connections with our websites or applications (such as newsletters), through social media pages that we control, as well as through text or email messages that we send to you (collectively, the “Sites”), and how that information may be collected, used, maintained and disclosed by us.

This Privacy Policy does not apply to information we collect through any other means, or to information collected on any affiliate or third-party sites or by any third-party applications that may link to or be accessible from the Sites. We do not have control over and are not responsible for third party use or disclosure of your personal information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites. By accessing or using our Sites, you agree to this Privacy Policy.

Children Under the Age of 13

Our Sites are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Sites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Sites or on or through any of its features, make any purchases through the Sites, use any of the interactive or public comment features of the Sites, or provide any information about yourself to us (including, without limitation, 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 may have personal information from or about a child under the age of 13, please contact us at info@affinitysales.com

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the “Your California Privacy Rights” section below for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Sites, including information:

  • By which you may be personally identified (such as name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline;
  • That is about you but individually does not identify you;
  • About your internet connection, the equipment you use to access our Sites, and usage details.

We collect information:

  • Directly from you when you provide it to us;
  • Automatically as you navigate through the Sites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies;
  • From third parties, for example, our business partners.

Information You Provide to Us.
The information we collect on or through our Sites may include:

  • Information that you provide by filling in forms on our Sites. This includes information provided at the time of registering to use our Sites, subscribing to our service, posting material, or requesting further services. 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 Sites;
  • Records and copies of your correspondence (including email addresses), if you contact us;
  • Your responses to surveys and contests;
  • Your requests for newsletters or other publications;
  • Details of transactions you carry out through our Sites and of the fulfillment of your orders. Your search queries on the Sites.

Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Usage Details and IP Addresses. As you navigate through the Sites, we may also collect details of your visits to our Sites, including, but not limited to, traffic data, location data, logs and other communication data, and the resources that you access, as well as information about your computer and internet connection, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ equipment, browsing actions and patterns, and does not identify any individual.
  • Cookies. For the same reason, we may obtain information about your general internet usage by using cookies. A cookie is a small file stored on the hard drive of your computer. Use of cookies help us to improve our Sites and to deliver a better and more personalized service by enabling us to:
    • Estimate our audience size and usage patterns;
    • Store information about your preferences, allowing us to customize our Sites according to your individual interests;
    • Speed up your searches;
    • Recognize you when you return to our Sites.

You may refuse to accept 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 Sites. 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 Sites.

  • Web Beacons. Pages of the Sites may contain electronic images known as web beacons (also referred to as single-pixel gifs) that permit the Company to count users who have visited those pages and for other related Sites statistics (for example, recording the popularity of certain Sites content and verifying system and server integrity). Web beacons are not used to access your personal information on the Sites and are only used to compile aggregated statistics concerning use of the Sites. Web beacons used by us on the Sites collect your IP address information, your internet provider name (or your company name if you host your own server).

Third Parties – and their use of Cookies and other Tracking Technologies
We may receive your personal information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.

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 Sites and its contents to you;
  • To provide you with information, products, or services that you request from us;
  • To fulfill any other purpose for which you provide it;
  • To provide you with notices about your account;
  • To provide, support, personalize, and develop our Sites, products, and services;
  • To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, and business;
  • For testing, research, analysis, and product development, including to develop and improve our Sites, products, and services;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • To notify you about changes to our Sites or any products or services we offer or provide though it;
  • To allow you to participate in interactive features on our Sites;
  • 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-party goods and services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements. 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. For more information, see the “Choices About How We Use and Disclose Your Information” section below.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclose personal information that you provide via the Sites to the following third parties:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties we use to support our business;
  • To fulfill the purpose for which you provide information to us;
  • For any other purpose disclosed by us when you provide the information;
  • For any other purpose with your consent.

We may also disclose your personal information to third parties to:

  • Comply with any court order or other legal obligation;
  • Enforce or apply our Terms of Use and other agreements;
  • Protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

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 cookie settings, visit your browser’s Help section.. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for 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 sending us an email with your request to info@affinitysales.com
  • Promotional Offers. If you do not wish to have your email address or other contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request to info@affinitysales.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience or other transactions.

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 receiving targeted ads from members of the Network Advertising Initiative on their website.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” section below for more information.

Accessing and Correcting Your Information.

You can review and change your personal information updating that information or by sending us an email at info@affinitysales.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.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” section below for more information.

Your California Privacy Rights

California Civil Code permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at info@affinitysales.com
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, and consult our Privacy Notice for California Residents, see below.

Data Security

We have data security measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted. Unfortunately, the transmission of information via the internet is not completely secure. The safety and security of your information also depends on you. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. 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 Sites.

Changes to Our Privacy Policy

This Privacy Policy may change from time to time. It is our policy to post any changes we make to our Privacy Policy on our website at info@affinitysales.com Your continued use of the Sites after we make changes is deemed to be your acceptance of those changes, so please check periodically for updates.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: info@affinitysales.com.

 

 

Privacy Notice for California Residents

Effective Date: January 1, 2020

This Privacy Notice for California Residents supplements the information contained in the Affinity Group (“Company”, “we”, “us”, “our” or “Affinity Group”) Privacy Policy available at info@affinitysales.com and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. All other capitalized terms shall mean as defined in the Privacy Policy.

Information We Collect

Our Sites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

 

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

 NO
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

 

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

We obtain the categories of personal information listed above from the following categories of sources as described in our Privacy Policy.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the purposes as disclosed in our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We share your personal information with third parties as descried in our Privacy Policy, and we may disclose your personal information to a third party for a business purpose, subject to your right to opt-out.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed personal information for the following business purpose of marketing and promotion of our agency.

We disclose your personal information for a business purpose to third parties with whom we have a business relationship as well as with our service providers.

Sales of Personal Information

We do not sell your personal information to any third parties.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the “Exercising Access, Data Portability, and Deletion Rights” section below), we will disclose to you:

  • The categories of personal information we collected about you;
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purpose for collecting or selling that personal information;
  • The categories of third parties with whom we share that personal information;
  • The specific pieces of personal information we collected about you;
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see the “Exercising Access, Data Portability, and Deletion Rights” section below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at info@affinitysales.com, or by mail at Affinity Group, 8811 Sidney Circle, Charlotte, NC 28269.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see the “Personal Information Sales Opt-Out and Opt-In Rights” section below.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will seek to inform you of the reason and extension period.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by email at info@affinitysales.com. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@affinitysales.com.

Changes to Our Privacy Notice

This Privacy Policy may change from time to time. It is our policy to post any changes we make to our Privacy Policy on our website at affinitysales.com. Your continued use of the Sites after we make changes is deemed to be your acceptance of those changes, so please check periodically for updates.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at info@affinitysales.com.