Date of Last Revision: July 26, 2022
HC 5300 Culver, LLC, together with its affiliates (collectively referred to herein as “Culver Steps”, “we”, “us”, or “our”), provides this Privacy Policy to explain our information practices in connection with our websites (“Sites”) and business, and when you otherwise provide information to us. This Privacy Policy applies to information we collect (1) when you visit and use our websites, (2) when you email us, submit forms, or otherwise contact us, and (3) when you make investments with us (collectively, our “Services”).
Culver Steps reserves the right to change this Privacy Policy at any time by posting a new or updated privacy policy through the Sites. We will use the reasonable means available to us in order to make you aware of any update of this Privacy Policy. However, we recommend that you review such Privacy Policy periodically for changes.
By using our Services, you indicate your agreement to and acceptance of the terms of this Privacy Policy, and consent to the collection, retention and use of your Personal Information consistent with this Privacy Policy, as amended from time to time.
Personal Information We Collect and How We Collect It
How We Use Your Personal Information
When We Share Your Personal Information
Security of Data Stored by Culver Steps
Collection of Personal Information From or About Children
Rights for California Residents
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Personal Information We Collect and How We Collect It
When we use the term “Personal Information,” we mean information from or about an identifiable person or that we can associate with an individual person, such as a real name, postal address, e-mail address, telephone number, payment or other financial information, or location information. When other information is directly associated with Personal Information, such as bank account information, we treat this other information as Personal Information. Information that is public, aggregated, de-identified, or anonymized, or otherwise exempted from data privacy laws, will not be considered Personal Information with respect to rights under those laws.
We may collect or process the following categories of Personal Information about you:
- Contact Information. You may choose to affirmatively provide information about yourself to us in connection with our Services or otherwise, including your name and contact information (including email address and postal address). For instance, if you fill out our “Become an Insider” form to receive updates about The Culver Steps and information about deals and events, we will collect your first name, last name, and email address. You can choose not to provide us with this Personal Information.
- Financial Information. If you enter into business with us, we may collect your financial information, including bank name, account number, and routing information.
- Technical Information. We also may collect certain technical and other information automatically generated by your device about how you use the Sites for the operation and improvement of the Sites. Such information can entail collection and processing of browser information, operating system information, unique device identifiers or your IP address, referring Sites, visit metrics, action metrics, page view metrics, search metrics, and others.
- Website Usage. This information may be collected through technologies provided by third parties. Information that might be collected using these technologies includes, for example, the pages you visit on the Sites, the paths you take within the Sites, and the length of time that you spend on the Sites. We use this information in the aggregate in order to better understand how to improve the quality of the Sites.
Cookies
Like many websites, the Sites also uses cookies or similar technology referred to as pixel tags (collectively, “cookies”). A cookie is a small text file that a web server gives your browser to store on your computer when you access a website. Cookies are capable of storing many types of data and may be placed on your browser by Culver Steps. We may also use cookies to store preferences; record session information; develop information about visitors’ preferences and interests; record past activity in order to provide better service when you return to the Sites; or customize web page content based on information you voluntarily provide.
Most web browsers are set up to accept cookies. You can, however, reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of the Sites may not work properly if you refuse cookies.
How We Use Your Personal Information
We do not sell your Personal Information.
We may use your Personal Information in the following ways:
- To communicate with you and send you materials we think you may be interested in. When you voluntarily give us information—for example, through an online form on our Site to register your support or receive project updates—including name, contact information (e.g., email address and postal address), and company name, or otherwise contact us, we may use this information to contact you directly, and send you materials and other items. We may also target advertising, marketing, or notification materials to you based on information you provide, including, for example, your zip code. If we contact you by email in compliance with applicable law, you can in any case opt-out of receiving future emails from us at any time by following the instructions in the email or notifying us at opt-out@theculversteps.com.
- To improve our products and Services, and perform analyses on the information we collect. We collect information to generally improve, develop, and understand our products and Services, including improving our Sites, soliciting feedback regarding our Services, and understanding and analyzing support for our projects and Services.
- To provide you with Services you or others request. For example, if you request us to include you on a newsletter, or publish your name as a supporter, we will use your information to fulfill your request.
- To publish and market our Services. If you provide us your information, and elect to permit us to use your name publicly as a supporter for our projects, we will use it to publish and market our Services.
We may also process your Personal Information for the additional following purposes: (i) to protect and defend the rights of Culver Steps and its employees, the Sites and Services, or the users of the Sites and Services; (ii) as incident to a sale, merger, reorganization, dissolution, bankruptcy, or similar event; (iii) under circumstances we believe reasonably necessary to protect the personal safety of users of Culver Steps products and Services the Sites, or the public; (iv) to complete any transaction initiated by you on the Sites or to provide Services or information to you; or (v) as is otherwise described in this Privacy Policy or to the extent that you otherwise consent to in writing.
When We Share Your Personal Information
Please note that your Personal Information may be shared with limited third parties: (i) our affiliates; (ii) third-party service providers we hire to assist with our Services, including in the administration of our Sites, for advertising and marketing purposes, and for consulting (such service providers are required to maintain the confidentiality of user information and are prohibited from using it for any purpose other than as described in this Privacy Policy); (iii) competent authorities, as required by law, such as when compelled by subpoena or court order; (iv) third parties in charge of measuring the effectiveness of our programs and advertisements. We do not sell your Personal Information.
The information you provide will be maintained for a commercially reasonable period of time by Culver Steps for administrative, liability, and archival purposes, but in no event for longer than seven (7) years after the termination of our contractual relationship.
Third-Party Links
The Sites may contain links to third-party websites. Please recognize that we do not control these third-party websites, or how they may collect or use information that you may provide to them. Your use of third-party websites, along with the use of any information that such websites may collect from you, are not governed by this Privacy Policy. You should consult each applicable privacy policy before using another linked website.
Do Not Track
Because we may use the information that we collect through the Sites in the ways described in this Privacy Policy, we do not respond to “Do Not Track” requests or other similar mechanisms.
Security of Data Stored by Culver Steps
Culver Steps has security measures in place to protect the loss, misuse, and alteration of information under our control. While we make reasonable efforts to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third parties from illegally obtaining this information. You agree and acknowledge that Culver Steps shall not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security of your communications or Personal Information has been compromised, please immediately notify us at: privacy@theculversteps.com.
Collection of Personal Information From or About Children
The Sites are not intended or designed to attract children under the age of 16. We do not knowingly collect or process Personal Information from persons under age 16. If we learn that we have collected the personally identifying information of a user under the age of 16, we will take steps to delete the concerned information. If you have reason to believe that Culver Steps has collected information from persons under 16, please notify us at: privacy@theculversteps.com.
We do not sell the Personal Information of children under the age of 16, or any Personal Information.
Your Rights
If you have any questions about this Privacy Policy, please send an email containing your request to privacy@theculversteps.com. You must provide your full name and email address.
In addition, if you no longer wish to receive communications from us, you may opt out at any time by notifying us at opt-out@theculversteps.com.
Rights for California Residents
The California Consumer Privacy Act of 2018, California Civil Code Sections 1798.100 et seq. (CCPA), may additionally afford rights to our users and customers who are California residents, with respect to Personal Information as defined by the CCPA. For example, California residents may have a right to:
(1) know about the Personal Information we have collected about you and make a request—twice in a 12-month period, free of charge— for information about the categories and specific pieces of personal information we have collected about you during the 12-month period prior to the request; and
(2) request deletion of personal information under certain circumstances.
Culver Steps does not discriminate against our users and customers on the basis of their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title. While the CCPA also allows consumers to opt out of the sale of personal information, we do not sell personal information.
California residents may exercise the rights described above by submitting a verifiable request to us by contacting us using the information outlined described below. We will first acknowledge receipt of your request within 10 business days after receipt of your request. We will provide a substantive response to your request within 45 calendar days after its receipt. If we require more time (up to 90 days or the permitted timeframe), we will inform you of the reason and extension period in writing. We will verify your identity using information you have previously provided to us. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us. We may ask you to verify your name, contact information, and other information you may have provided us, in order to verify your identity.
If you have any questions regarding our Privacy Policy, need to access the policy in an alternative format due to a disability, or if you would like to access, update, or delete your personal information, please contact us by emailing privacy@theculversteps.com or by telephone at 1 (844) 990-0793.
California Shine the Light
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. Culver Steps does not share Personal Information to third parties for third parties’ direct marketing purposes.
Contact Us
If you have any questions regarding our Privacy Policy, please contact us at privacy@theculversteps.com.