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Privacy Policy

This Privacy Policy was last updated May 18, 2018.

This policy describes the personal information collected by Small Victories, Inc. LLC ("Small Victories, Inc.," "we" or "us") on its sites, which include but are not limited to https://www.smallvictori.es, as well as our mobile sites and native apps (together as the "Sites"), why we collect it, how we use it, and when we share it with third parties. The policy also covers the online experiences and services provided by Small Victories, Inc. through the Sites (the "Services"). By visiting the Sites, registering as a member, or using the Services, you acknowledge and accept the practices and policies outlined in this privacy policy ("Privacy Policy"). Unless otherwise defined herein, capitalized terms shall have the meanings assigned to them in the Small Victories Terms & Conditions, which can be found at Terms & Conditions and which incorporate this Privacy Policy by reference. If you do not agree to the terms of this Privacy Policy or the Terms & Conditions, you may not use the Sites.

"Personal Information" is information that is personally identifiable such as names, addresses, e-mail addresses, personal URLs, photographs, phone numbers and credit card numbers. We collect and use Personal Information as described in this Privacy Policy from the Users of our Services.

By using the services or submitting personal information through the services, you expressly consent to the processing of your personal information according to this Privacy Policy. Your personal information may be processed in the country where it was collected as well as other countries (including the United States) where laws regarding processing of personal information may be less stringent than the laws in your country.

Information We Collect and Opting Out of Automatic Collection

We collect the following information that you submit to us voluntarily:

• Our Member registration process to create an Account requires you to provide us with your e-mail address and a username and password of your choice. We also save your acceptance of our terms during that process.

• As you use the Services, certain information may also be collected passively, including your Internet protocol (IP) address and the browser that you use to visit the Site. Small Victories, Inc. may also use "cookies," "pixel tags" and other tracking technologies, to enable functionality on our websites, as well as a variety of other ways to enhance or personalize your online browsing. Small Victories, Inc. may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) for a variety of tasks, for instance, to store your login information (if any) and your personal preferences for the Services. Pixel tags in our emails may be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. These technologies may also be used to collect information about your visit, including the pages you view, the features you use, the links you click, other actions you take in connection with the sites and our online ads.

• We also work with third-party companies that use their tracking technologies (including cookies and pixel tags) on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information about your activity on our sites and your interaction with our advertising and other communications and use this information to determine which ads you see on third-party websites and applications.

• You have the option to set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. If you do not accept cookies, however, you may not be able to access your account information and certain parts of the Services may not function as effectively or at all.

• Please note that even if you opt-out, ad tracking technologies may still collect data and you will still see ads, but they will not be targeted based upon the information collected through these tracking technologies.

• We may combine the information we collect through these various technologies with other information we have collected from and about you and use it as described in this policy.

Information Collected from Other Sources

We may receive Personal Information about you from outside the Sites, for instance, from third parties that provide services for us that are related to the Services. We may add this information to the information we have already collected from you via our Services. We will treat such information (e.g. for verifying an identity) in accordance with this Privacy Policy and remove extra information we received immediately if not needed anymore. Should personal data be updated within third party services that are connected to our Service, we reserve the right to adopt those changes in order to keep up the reliability of our Service.

Use of Information We Collect

In general, information (including Personal Information) we collect is used by us to provide you and other Users with the Services, respond to requests that you make, including performing technical support, to improve the Sites and Services, to better tailor the features, performance and support of the Services, and to perform investigations consistent with this Privacy Policy.

We may also use your Personal Information to provide you with announcements, notifications related to your use of the Services and other communications such as electronic newsletters, promotional e-mails or similar messaging.

We may create anonymized information from Personal Information by excluding information (such as your name) that makes the information personally identifiable to you. We may use this anonymized information for internal purposes, such as analyzing usage patterns so that we may enhance the Services, and we also reserve the right to use and disclose such anonymized information at our discretion.

Disclosure of Personal Information

Except as otherwise stated in this Privacy Policy, we do not disclose to or share your Personal Information with third parties, unless you ask or authorize us to do so.

We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with some of the services and features of the Services and to help us communicate with our Users, for instance, to get User feedback or conduct services and to process payments that are related to your account. However, these service providers and suppliers do not have any independent right to use this information except to help us provide the Services.

We may share some or all of your Personal Information with any parent company, subsidiaries, joint ventures, or other companies under a common control (collectively, "Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.

In the event Small Victories, Inc. goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, including pursuant to bankruptcy, you acknowledge that your Personal Information may be among the assets transferred.

We may (and you authorize us to) disclose or retain, for as long as is reasonably necessary to accomplish the below, information we have collected from and about you (including Personal Information) if we believe in good faith that such disclosure or retention is necessary to:

  1. (a)comply with relevant laws or to respond to valid subpoenas or warrants served on us or to other government requests;
  2. (b)to enforce our Small Victories, Inc. Terms & Conditions and Privacy Policy; or
  3. (c)to protect and defend the rights or property of us, the users of our Services, or third parties.

Choices Regarding Your Information

You may change your Personal Information (e.g. password and/or username) by logging into the service and editing your account information from within the Settings area of your profile. You can also review, update, and remove certain account information by sending an e-mail to us at [email protected]. We may require additional information from you to allow us to confirm your identity. We will respond to your request as soon as possible, but by no later than 30 days. If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority.

We may provide you with the opportunity to 'opt-out' of having your Personal Information used for certain purposes, when we ask for this information.

We may send newsletters, promotional communications or other similar messaging to our users on our behalf and on behalf of our partners. You may opt-out of receiving such messaging by following the instructions included in each message. We may also offer you an opportunity to opt-out of certain communications by logging into the service and editing your account information from within Settings.

We may send you service-related announcements when we believe it is necessary to do so. Generally, you may not opt-out of these announcements, which are not primarily promotional in nature. If you do not wish to receive these announcements, you have the option to deactivate your Account.

We may notify you when your Personal Information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.

You may terminate your account by discontinuing your use of the Sites and providing us with a notice of termination by email to [email protected] Victories, Inc..co. After we receive this notice we will delete your account within a commercially reasonable amount of time, however, we reserve the right not to delete your Account and to retain your Account, including any Personal Information therein, to establish or defend a legal claim, pursuant to a government order or for other purposes permitted by law. Any termination of your account may involve deletion of your Account information from our live databases and all the information and data stored for such Account in the Services. Small Victories, Inc. will not have any liability whatsoever to you for any termination of your account or related deletion of you information.

If and when we delete Personal Information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives unless otherwise required by law.

Duration of Date Storage

We store your information as long as we need it in order to provide you with our Service. If you delete your account, we will also delete this information. Some time may pass between deleting it from our servers and removing them from our backup storage. We may retain this information in order to comply with our legal obligations, settle disputes, or enforce our contracts.

Protection of the Data

The personal data is stored encrypted. We constantly strive to improve the system for data protection, to check and to ensure its functionality. To save your data a guard system is implemented that allows threat detection and continuous monitoring.

Cross-Border Data Transfer

This Privacy Policy is governed by United States law. If you are visiting our Service from outside the United States. Your information may be transferred across borders, and from your country or jurisdiction of residence to other countries or jurisdictions around the world, including to the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries may differ from those in your country. By using our Service, you are expressly consenting to the transfer to and from, and processing, usage, sharing, and storage of your information in the United States as well as other jurisdictions where Connected Ventures conducts business or providers services. If your data is collected in the European Union, we will transfer your personal data subject to appropriate or suitable safeguards and you may contact us for more information via [email protected].

Other Web Sites

The Services may contain links to other web sites that are not owned or controlled by Small Victories, Inc.. The provision of such links is for your convenience and does not signify our endorsement of such web sites or location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other web sites. Our Privacy Policy does not apply to any outside web sites.

Additionally, third parties may host their own sites through functionality provided through the Services (“User Sites”). We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such User Sites and Our Privacy Policy does not apply to these User Sites.

Advertising

We may allow advertisers to place advertisements on the Sites (but not the User Sites). Clicking on such advertisements will direct you to the website of a third party. These websites may use tracking technologies in connection with these advertisements and may collect information from you, which may include Personal Information. This Privacy Policy does not cover the collection of information by these third-party websites. For information about our advertising partners, please visit their websites through the links included in the presentation of the advertisements.

Additionally, users of the services may choose to place advertisements on the User Sites. The User Websites and the ads placed thereon by may use tracking technologies and may collect information from you, which information may include Personal Information. This Privacy Policy does not cover the collection of information by these User Sites. Please visit individual User Sites to view their privacy policies, as applicable.

Privacy of Minors and Children

We do not intentionally collect or maintain information in the Services from those visitors and Users of the Services who are under 18 years old. Pursuant to the Children's Online Privacy Act (COPPA), we do not knowingly contact or collect personal information from children under thirteen (13). In fact, our website is not intended for children under thirteen (13) or to solicit information of any kind from children under thirteen (13).

However, it is possible that we may inadvertently receive information pertaining to children under thirteen (13). If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen (13) we will delete the information from our records. If you believe that we have received information about your child that is under the age of thirteen (13), please do not hesitate to notify us using the information below. When we receive your notification, we will delete such information permanently. Such notifications can be sent to: [email protected] Victories, Inc..co

Security Safeguards

Small Victories, Inc. has put in place commercially reasonable and appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, no company, including Small Victories, Inc., can fully eliminate security risks associated with Personal Information. Your use of the Sites and Services is at your own risk.

Public Postings

One of the purposes of the Services is for Members to share information with other Users. Therefore, you should assume that any information that you post to the publicly available areas of the Sites will be made available to other Users of the Services and the public at large.

Feedback

If you provide feedback about the Services to us, we may use and disclose such feedback for any purpose, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

Changes to this Statement

Notice of any changes to this Privacy Policy will be made as described in Terms and

Conditions

We reserve the right to modify this statement at any time, so please review it frequently. If we make material changes to this policy, we may notify you here, by email, by means of a notice on our home page, or by another method we so choose.

Your California Privacy Rights

California Civil Code Section 1798.83 permits Members of the Sites who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Under California law, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with our affiliates and/or third parties for marketing purposes, and provide contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to:

Small Victories, Inc.
411 E 9th Street
Storefront East
New York, NY 10009

ATTN: California Privacy Requests

[email protected]

Do Not Track

While many current browsers permit you to send a signal to us about your Do Not Track ("DNT") preferences, we do not respond to DNT signals sent from your browser.

International Users

Small Victories, Inc. makes no claims that user content uploaded may be appropriately protected pursuant to privacy and data protection laws outside of the United States. Users from outside the United States, including the European Union, are advised that Small Victories, Inc. stores personal information on servers within the United States, and they are further advised that personal information uploaded to the Sites may not be protected in accordance with their local laws and regulations. If you upload personal information to the Sites from outside the United States, you do so at your own risk. Small Victories, Inc. is not responsible for compliance with the laws of your jurisdiction and makes no representations, warranties or guarantees that it complies with privacy, data protection or cyber security laws and regulations outside the United States.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy please contact us by sending us an e-mail to [email protected].

Small Victories