Privacy Policy

Effective date: August 1, 2022

At Partake Collective Manager LLC, a Delaware company (hereinafter, “Company,” “us,” or “we”), we respect and protect the privacy of visitors to our website, www.insert.com, and the other websites under the insert.com domain (collectively, the “Sites”), and our customers who use our product, tools, and related services (together with the Sites, the “Service”).

This Global Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect visitors’ and users’ information as part of the Service. Any discussion of your use of the Service in this Policy is meant to include your visits and other interactions with the Sites and Services, whether or not you are a customer of “Company”. If you are a resident of the European Union, European Economic Area, or Switzerland, please read the GDPR section for further information about our data collection practices and your rights.

Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service.

By accessing and using our Service, you signify your acceptance to the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

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This Privacy Policy describes how 5x5marketing.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Contact

After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to make a complaint, please contact us by e-mail at info@partakecollective.com or by mail using the details provided below:

To:  Privacy Officer

Partake Collective

18881 Von Karman Ave, Ste 1625

Irvine, CA 92612

1. What “Personal Information” means

In this Policy, “Personal Information” means information or an information set that identifies or could be used to identify an individual directly or indirectly. Except as described in this Policy, “Company” will not give, sell, rent, or loan any Personal Information to any third party.  Personal Information does not include “Usage Data” which we define as encoded or anonymized information or aggregated data we collect about a group or category of services, features, or users which does not contain personally identifying information. Usage Data helps us understand trends in usage of the Service so that we can better consider new features or otherwise tailor the Service. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information about an identifiable individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

  • Device information
  • Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
  • Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
  • Disclosure for a business purpose: shared with our processor Square, shipping partners and our ESP, Klaviyo.
  • Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
  • Order information
  • Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
  • Source of collection: collected from you.
  • Disclosure for a business purpose: shared with our processor Square, Google, Meta, USPS, UPS, FedEx, PayPal, Google Pay, Amazon, Walmart, Pinterest, and Apple Pay.
  • Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers or logins for digital payment), email address, and phone number.
  • Customer support information
  • Purpose of collection:
  • Source of collection:
  • Disclosure for a business purpose:
  • Personal Information collected: 
  • Purpose of collection: to provide customer support.
  • Source of collection: collected from you
  • Disclosure for a business purpose: Klaviyo, Google, Google Voice
  • Personal Information collected: FROM TIME TO TIME, WE MAKE MODIFICATIONS TO THE INFORMATION LISTED ABOVE OR ADDITIONAL INFORMATION AS NEED.

Minors

The Site is not intended for individuals under the age of 13. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address above to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

  • We use Webflow to power our online store. You can read more about how Webflow uses your Personal Information here: https://webflow.com/legal/privacy
  • We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful requests for information we receive, or to otherwise protect our rights.

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Behavioral Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

  • We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
  • We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
  • We use Klaviyo for outbound email marketing and sms marketing.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt-out of targeted advertising by:

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

The Company does not sell personal information collected through the Website in exchange for any monetary consideration

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

  • Your consent;
  • Compliance with our legal obligations;
  • To protect your vital interests;
  • To perform a task carried out in the public interest;
  • For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We DO NOT engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Square uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

  • Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
  • Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.

Selling Personal Information

Our Site does not sell Personal Information, as defined by the California Consumer Privacy Act of 2018 (“CCPA”).

Your rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. 

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR.

CCPA

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the Personal Information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information, and the third parties with whom we may share your Personal Information.

We generally collect the following categories of Personal Information about you when you use our Site or services:

  • identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
  • protected classifications, such as gender;
  • commercial information such as records of products or services purchased, obtained, or considered by you;
  • Internet or other electronic information regarding your browsing history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
  • audio recordings of your voice to the extent you call us, as permitted under applicable law;
  • professional or employment-related information.

We generally do not collect education-related or biometric information, geolocation information, or inferences about your preferences, characteristics, behavior and attitudes. For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.

We collect your Personal Information for the business purposes described in Section 2, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.

  • Right Against Discrimination – You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
  • Right to Know – You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
  • Right to Delete – You have the right to request us to delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.

To assert your right to know or your right to delete your Personal Information, please contact us according to the “Contact Us” section below. To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

  • Right to Opt-Out of Selling. As described in this Privacy Policy, in certain situations we may share your Personal Information with certain third parties for our marketing or other purposes. To the extent such sharing is considered a “sale” under the CCPA, as a California resident you have the right to opt-out of such sharing. If you would like us to no longer share your Personal Information in this way, you can opt-out by visiting the following web page: Do Not Sell My Info. If you opt-out, we may be unable to offer you some of our Services which require sharing of Personal Information.

California consumers may also use the Digital Advertising Alliance’s tool to send requests under the California Consumer Privacy Act (“CCPA”) for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/, or by downloading the DAA’s AppChoices mobile application opt-out here:  https://www.privacyrights.info/appchoices.  

The AppChoices app is not limited to opt-outs for CCPA purposes and may be used by anyone to limit the collection of cross-app data for interest-based advertising purposes by participating DAA member companies.

In addition, under California Civil Code Sections 1798.83–1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing 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: info@partakecollective.com

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If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. 

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address above.

Cookies

A cookie is a small amount of information that is downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance, whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Please refer to our Cookie Policy.  The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioral Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Complaints

As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority or our supervisory authority.

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Last updated: September 2022

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