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Privacy Policy
Last updated: May 29th, 2018
Introduction
Protecting your private information is our priority. We have taken all of the steps necessary to protect your personal information and to prevent security breaches.
Our website address is covina.com and the organization name is Covina Downtown Merchants Association with a mailing address of: PO Box 4671 Covina, California 91723. Covina Downtown Merchants Association ("us", "we", or "our") operates the covina.com website (the “Site”). This Statement of Privacy applies to covina.com and the Covina Downtown Merchants Association (CDMA), CDA, Thunderfest and/or Bluesapalooza and governs data collection and usage.
The Covina Downtown Merchants Association website is an informational website with a directory of its members. By using the Covina Downtown Merchants Association website, you consent to the data practices described in this statement.
Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible from https://covina.com/terms-of-use/.
- Site: Site is the covina.com website operated by Covina Downtown Merchants Association of which this Privacy Policy applies.
- Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
- Usage Data: Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, while you are visiting a page on covina.com, we may collect data on which pages you visited and which links you clicked on).
- Cookies: Cookies are small pieces of data stored on your device (computer or mobile device).
- Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. What does that really mean? For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data, meaning Covina Downtown Merchants Association determines why and how your personal information will be processed.
- Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively and to more accurately and more easily provide our product or service to you. In an effort to give you control over your personal information, Covina Downtown Merchants Association provides a list of those Service Providers and how your information is being under the Storage and Transfer of Your Data section.
- Data Subject (or User): Data Subject is any living individual who is using our Site and is the subject of Personal Data. The Data Subject is you and is often called the “user” or “consumer”.
Collecting Your Personal Information
We collect several different types of information from you for the purposes of providing and improving our product or service to you, analyzing website functionality, or to diagnose and track errors or glitches. Below are the types of data we collect:
While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). We do not collect any Personal Data about you unless you voluntarily provide it to us. This is a list of the types of Personal Data we collect from you how we store it, and how we dispose of it: [Personal Data Table].
You may be required to provide certain Personal Data to us when you elect to use certain products or services available on covina.com. These may include: (a) registering for an account or leaving a comment on covina.com; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message through use of the contact form or by direct email; (e) submitting your credit card or other payment information when ordering and purchasing products and services on covina.com.
We will use your Personal Data for the following:
- To contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
- Communicating with you in relation to services and/or products you have requested from us.
- Processing your online order, delivering your online products, or shipping/delivering your physical order.
We also may gather additional personal or non-personal information in the future but you will have the opportunity to provide consent before we collect any more of your Personal Data.
Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
We may also collect information about how the Site is accessed and used (“Usage Data"). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We collect Usage Data for the operation of the Site, to maintain the quality of the Site, to improve your user experience, and to provide general statistics regarding use of the Covina Downtown Merchants Association website.
We use cookies and similar tracking technologies to track the activity on our Site and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Site.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
Examples of Cookies we use:
- Session Cookies: We use Session Cookies to operate our Site.
- Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
- Security Cookies: We use Security Cookies for security purposes.
- Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
How We Use Cookies on covina.com
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year. If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select "Remember Me", your login will be retained for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded Content From Other Websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Covina Downtown Merchants Association may collect anonymous demographic information, which is not unique to you, such as your:
- Age
- Gender
This information is collected to obtain anonymous demographic data about the users of our Site in order to analyze and improve the way our Site functions.
Covina Downtown Merchants Association uses the collected data for various purposes:
- To provide and maintain our Site.
- To notify you about changes to our Site.
- To allow you to participate in interactive features of our Site when you choose to do so.
- To provide customer support.
- To gather analysis or valuable information so that we can improve our Service.
- To monitor the usage of our Site.
- To detect, prevent and address technical issues.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
The Storage and Transfer of Your Data
Covina Downtown Merchants Association will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Covina Downtown Merchants Association will not retain your creditor debit card information on covina.com or any other online service. Only the approved service providers under the General Information section will retain access to your credit or debit card details.
Covina Downtown Merchants Association will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, may be transferred to (and maintained on) computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Covina Downtown Merchants Association will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Covina Downtown Merchant Association does not sell, rent or lease its customer lists or its users’ Personal Data to third parties.
Covina Downtown Merchant Association may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Covina Downtown Merchant Association, and they are required to maintain the confidentiality of your information.
Below is a list of places where Covina Downtown Merchant Association keeps your personal information and the way your data is transferred between them.
Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Site available to Google Analytics by installing the Google Analytics opt-out browser add- on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
We may use third-party Service Providers to show advertisements to you to help support and maintain our Site.
Google AdSense & DoubleClick Cookie: Google, as a third party vendor, uses cookies to serve ads on our Site. Google's use of the DoubleClick cookie enables it and itYous partners to serve ads to our users based on their visit to our Site or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://var/web/site/public_html.google.com/ads/preferences/
Facebook: Facebook re-marketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://var/web/site/public_html.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://var/web/site/public_html.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://var/web/site/public_html.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://var/web/site/public_html.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://var/web/site/public_html.facebook.com/privacy/explanation
Google Web Fonts: For uniform representation of fonts, this website uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google's privacy policy at https://var/web/site/public_html.google.com/policies/privacy/.
Eventbrite: Eventbrite is an event management and organization platform with ticket sales. We provide external links to our Organizer page and events on Eventbrite from our covina.com website. When you click on an Eventbrite link from on of our pages, a connection to the Eventbrite servers is established. Here the Eventbrite server is informed about which of our pages you have visited.
Further information about handling user data and what kind of data Eventbrite collects from you can be found on their website: https://var/web/site/public_html.eventbrite.com/support/articles/en_US/Troubleshooting/eventbrite-privacy-policy?lg=en_US
Mailchimp: Mailchimp is an email marketing website that we use to share news and specials with you. If you purchase tickets and consent to receive emails from us, your Personal Data (full name and email address) will be shared with Mailchimp through encryption in order for us to provide you with those emails.
Mailchimp stores your Personal Data for as long is necessary to provide the service to you. However, you may unsubscribe at any time by clicking the "Unsubscribe" links at the bottom of our emails or by doing so here by list type:
Downtown Covina Fans: Unsubscribe
Thunderfest Vendors: Unsubscribe
Thunderfest Cars: Unsubscribe
For further information on handling user data or what Mailchimp collects from you can be found here: https://mailchimp.com/legal/privacy/
Under certain circumstances, Covina Downtown Merchants Association may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Covina Downtown Merchants Association may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary:
- To conform to the edicts of the law or comply with legal process served on Covina Downtown Merchants Association or the site.
- To protect and defend the rights or property of Covina Downtown Merchants Association.
- To act under exigent circumstances to protect the personal safety of users of Covina Downtown Merchants Association, or the public.
- To protect against legal liability.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As a result, you acknowledge that:
- There are security and privacy limitations inherent to the Internet which are beyond our control.
- Security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.
Covina Downtown Merchants Association makes every reasonable effort to secure your Personal Data from unauthorized access, use, or disclosure. Covina Downtown Merchants Association uses the following methods for this purpose:
- SSL Protocol: When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.
GDPR (General Data Protection Regulation) Policies
If you are from the European Economic Area (EEA),Covina Downtown Merchants Association’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Covina Downtown Merchants Association may process your Personal Data because:
- We need to perform a contract with you.
- You have given us permission to do so.
- The processing is in our legitimate interests and it's not overridden by your rights.
- For payment processing purposes.
- To comply with the law.
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If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Covina Downtown Merchants Association aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Covina Downtown Merchants Association relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Data Breach Procedure and Response Policy
This policy outlines the processes to be followed in the event that a Downtown Merchants Association experiences a data breach or suspects that a data breach has occurred. A data breach involves the loss of, unauthorized access to, or unauthorized disclosure of, personal information.
When a privacy data breach is known to have occurred, or is suspected, a site admin of covina.com who becomes aware of this must alert the DPO (Data Protection Officer) or Privacy Officer within 24 hours. The information included in this alert consists of:
- Time and date of breach.
- Description of breach and type of Personal Data involved.
- Cause of the breach, if known, as well as how it was discovered.
- Which systems are affected?
- Whether actions have been taken to correct or remedy the breach, or suspected breach.
Once the DPO or Privacy Officer of Covina Downtown Merchant Association is notified, the officer must determine whether or not a breach has actually occurred and make an assessment on the severity of the breach, or potential breach. Details of the report are as follows:
- Is Personal Data involved?
- Is the Personal Data of a sensitive nature?
- Has there been unauthorized access to personal information, unauthorized disclosure of personal information, or loss of personal information?
- Determining the severity of the breach through type and extent of Personal Data involved.
- Determining whether multiple individuals have been affected, whether the information is protected by any security measures (password protection, SSL encryption, etc.).
- Determining the person or groups who now have access and whether they pose a real risk of serious harm (physical, emotional, economic, or financial harm to reputation) to the affected individuals.
- Determining if there are Federal or State laws that may have been implicated by the breach, or suspected breach.
The DPO or Privacy Officer must issue internal notifications to the site admins and Covina Downtown Merchants Association officers to make aware of the breach, or potential breach, and the plan for managing and correcting the issue. The Data Breach Response Team will consist of:
- DPO or Privacy Officer
- Human Resources Manager (or CEO if no Human Resources Manager is appointed)
- Marketing Director
- Information Technology Manager or Webmaster
The DPO or Privacy Officer must submit a report to all Data Breach Response Team members consisting of initial Alert, Determined Impact, and Resolution Plan. The following steps will be taken:
- Contain the breach (if it has not already been contained) through retrieving the lost Personal Data, completely blocking unauthorized access, securing physical areas (server locations), and/or shutting down the affected systems.
- Collecting and documenting all available evidence of the breach.
- Reporting the breach to the governing agency: the FTC in the United States.
- Remove any improperly posted information from the web: If the data breach involved Personal Data which became posted on covina.com the Response Team must remove it and search other websites to make sure they do not have a saved copy of the Personal Data. In the case the Personal Data is posted on other websites, the DPO or Privacy Officer will contact those sites and ask them to remove it.
- All service providers of covina.com will be investigated and/or contacted to determine if they were the source of the breach. The Response Team will verify that the service providers have taken every step to remedy the vulnerability and ensure another breach does not occur.
The Marketing Director must issue the following public and private notifications:
- Through the use of a site-wide banner on covina.com, notify any resident of California whose unencrypted Personal Data was, or is reasonably believed to have been, acquired by an unauthorized person, according to the California S.B. 1386 bill.
- Notify local law enforcement of the potential risk for identity theft.
- Communicate the details of the breach, what Personal Data may have been affected, what steps Covina Downtown Merchant Association is taking or has taken to correct the breach, and recommendations to the user regarding changing their password on covina.com (if they have one) and any other suggestions to help prevent further Personal Data Breaches.
General Information
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
We may provide paid products and/or services within the Site. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
- Stripe: Their Privacy Policy can be viewed at: https://stripe.com/us/privacy
- PayPal or Braintree: Their Privacy Policy can be viewed at: https://var/web/site/public_html.paypal.com/webapps/mpp/ua/privacy-full
This Site may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Contact information
CDMA welcomes your questions or comments regarding this Statement of Privacy. If you believe that CDMA has not adhered to this Statement, please contact CDMA at:
Covina Downtown Merchants Association
PO Box 4671 Covina, California 91723
Email Address: board@covina.com
Telephone number: (626) 380-8204