This Privacy Policy (“Privacy Policy”) applies to your use of Sarah Pomponi’s (“Sarah Pomponi” or “we”) websites (collectively, this “Website”) and describes what kind of information Sarah Pomponi collects, when and how Sarah Pomponi might use that information, how Sarah Pomponi protects the information, and the choices you have with respect to your personal information.  Sarah Pomponi may change, add to, or remove all or any portion of this Privacy Policy at any time, and will post the current Privacy Policy so that you will always have the current Privacy Policy available to you. It does not apply to third-party websites, applications, or services.  Before accessing, using, or interacting with the Websites, you should carefully review the terms and conditions of this Privacy Policy. By using this Website, you are agreeing to Sarah Pomponi’s Privacy Policy, without modification, and confirming you have read and understand these policies, including how and why Sarah Pomponi uses your information.  If you do not want Sarah Pomponi to collect or process your personal information in the ways described in this Privacy Policy, you should not use the Website.

Personal Information Collection and Use

Sarah Pomponi collects information about you and your use of this Website through various means, including information Sarah Pomponi receives from you on website forms, as well as through your access, use, or interaction with this Website.  Such processing is utilized to provide this Website to visitors.Sarah Pomponi is not liable or responsible for any consequences resulting from the submission of this personally identifiable information through this Website. If you do submit this information, you do so at your own risk.

Personal Information You Provide to Sarah Pomponi

The following provides more detailed information on the personal information you provide to Sarah Pomponi and why it is collected:The Personal Information we may collect include your name, email address, password, postal address, phone number, gender, date of birth, occupation, employer information, photo, payment information (such as your credit or debit card and billing address), preference or interest data, and any other information you choose to provide.

Sarah Pomponi uses your information to send you updates that may be relevant to you regarding Sarah Pomponi events, activities, and news.  This information is necessary to send you the communications and information you have requested.

Personal Information Sarah Pomponi Automatically Collects

Sarah Pomponi automatically collects certain information and data when you use, visit or navigate this Website. Sarah Pomponi refers to this automatically collected information as “Device Information.” The information Sarah Pomponi collects could be aggregate and/or user-specific individual information but does not reveal your specific identity (like your name and/or contact information).  This information is primarily needed to maintain the security and operation of this Website and for internal analytics and reporting purposes.  This information includes device characteristics (including operating system and name), your IP address, browser characteristics, communication data, referring URLs (what web websites or search terms that referred you to the Websites), how and when you use our and other technical information, time zone, location, country, language preferences and patterns of use (information on the individual web pages or services you view on this Website, and browsing and navigation patterns within this Website).

Cookies

When you visit this Website, Sarah Pomponi collects Device Information using so-called “cookies” to make this Website more user-friendly, effective, and secure. A cookie is a small piece of data sent from a website and stored in a file on your browser. A cookie is useful for having the browser remember specific information across several pages or between visits to a website.

Sarah Pomponi does not store any sensitive information within your cookies. This Website does not read any information stored in cookies given to you from other websites, except in rare cases where the other website is a provider of information or functionality within this Website and that cookie is necessary to make this Website functions correctly.Most of the cookies Sarah Pomponi uses are “session cookies” which are automatically deleted as soon as you leave this Website. Other cookies, so-called “persistent cookies,” remain on your computer until you delete them. Using these cookies allow Sarah Pomponi to enhance your experience in interacting with this Website, such as by helping recognize your browser the next time you visit and loading previously viewed pages faster. Sarah Pomponi uses cookies to offer you the best possible experience on the Websites.

Sarah Pomponi also uses cookies to collect browsing information in order to improve your overall experience. Sarah Pomponi uses this information to track usage of this Website and compile statistics. This helps Sarah Pomponi improve this Website, so you will find it more useful and informative, and enable customized promotions you may be interested in. Sarah Pomponi may use the combination of data Sarah Pomponi collects, such as browsing information and email address, to join known devices together and provide you personalized experiences on the device you are currently using. Impression data from cookies, which indicates who has seen marketing and/or information about Sarah Pomponi’s services on this Website or third-party websites, may be used to improve Sarah Pomponi’s marketing practices.

Sarah Pomponi may use browsing information collected to match with information received from third parties (including behavioral information and device identifiers) and client information to learn more about an individual or a group. These actions help us analyze interactions with this Website, improve marketing efforts, inform Sarah Pomponi’s strategic approach and improve your experience. Sarah Pomponi also may use this information to directly market Sarah Pomponi’s services, to the extent permitted by law. Sarah Pomponi may use third parties to perform these and other activities. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. Browsers may also be set up to display a warning when a cookie is used. You may even disable your browser from accepting cookies. Disabling cookies is unique to each browser and device you use. Disabling cookies on one device will restrict the ability to tie that device to other devices you use. Parts of this Website may not function properly if you disable cookies. To provide you with the best possible experience while visiting this Website, please enable cookies within your browser.

Sarah Pomponi also enables cookies to be placed or accessed on your device by third party advertising networks. These kinds of persistent cookies remember the websites you visit, and that information is shared with other parties, such as advertisers. Sarah Pomponi may use third-party advertising networks to help deliver tailored online ads to you. To learn more about opting-out of this type of interest-based advertising, please visit the Network Advertising Alliance (NAI) Consumer opt-out website.

With whom does Sarah Pomponi share your information?

Sarah Pomponi only shares information with your consent, to comply with laws, to provide you with purchased services, to protect your rights, or to fulfill business obligations. Third parties who may receive your personal information include:

Non-affiliated service providers – These non-affiliated service providers may offer services like, but not limited to, payment processing, data analysis, email delivery, hosting services, customer service, marketing efforts, etc.  These companies may use information about your visits to this Website and other websites that are contained in cookies to provide services, advertisements, or to collect data about how you interact with this Website over time

Government and regulatory authorities – Sarah Pomponi may provide information to government and regulatory bodies to provide the services you have purchased or because of legal and regulatory obligations on Sarah Pomponi’s business.

Sarah Pomponi auditors and legal advisors – Sarah Pomponi may need to provide information to assist with provision of services or management of Sarah Pomponi’s business.

Others only as permitted by law

Sarah Pomponi does not sell your personal information, and Sarah Pomponi has contracts with service providers to prohibit any sale of your personal information and to provide written assurances regarding the security and privacy protections they have in place to protect your personal information. In the event there is a change in the corporate structure of Sarah Pomponi, such as, but not limited to, merger, consolidation, sale, liquidation, or transfer of substantial assets, Sarah Pomponi may, in its sole discretion, transfer, sell or assign personal information Sarah Pomponi has about you to one or more affiliated or unaffiliated third parties.

Where and how long is your personal information stored?

Sarah Pomponi stores personal information about you on computer systems operated by Sarah Pomponi or Sarah Pomponi’s service providers. Sarah Pomponi will maintain personal information about you for as long as necessary in connection with both Sarah Pomponi’s and your legal rights and obligations for the purposes for which it was collected, to defend or advance legal claims, or as otherwise required by applicable laws and regulations.

How is my personal information secured?

Sarah Pomponi maintains physical, technological and administrative safeguards to protect your personal information and prevent unauthorized or accidental use, access, or loss. Sarah Pomponi limits access to personal information about you to those who have a business need for such access. Individuals who process personal information on Sarah Pomponi’s behalf generally may do so only in an authorized manner and are required to keep your information confidential. Sarah Pomponi limits access to our premises and to our computer networks and takes steps to safeguard against unauthorized access to such premises and networks.

What are your rights?

You may have various rights with respect to your personal information depending on where you live, the information Sarah Pomponi has about you, and the context in which it was obtained. These rights are defined under a variety of privacy laws and regulations, each of which may or may not apply to our relationship with you or your personal information. Sarah Pomponi may choose to extend these rights to you even if we are not required to under applicable law.

Privacy Rights under the California Consumer Privacy Act (“CCPA”)

For residents of California, to the extent Sarah Pomponi has collected information about you, you may have rights to your personal information as described below:Right to know – You may be entitled to request that Sarah Pomponi disclose to you your personal information Sarah Pomponi has collected about you, the categories of sources from which Sarah Pomponi collected the information, the purposes of collecting the information, the categories of third parties with whom Sarah Pomponi has shared the information, and the categories of personal information that Sarah Pomponi has shared with third parties for a business purpose. Before providing any of this information, Sarah Pomponi must be able to verify your identity.Right to opt-out – Sarah Pomponi currently does not sell personal information to third parties, and therefore do not offer this option. Sarah Pomponi may share personal information about you with business partners and others as permitted by law. Please see the “With whom does Sarah Pomponi share your information?” portion of this Privacy Policy for more information.Right to deletion – Subject to certain conditions, you may be entitled to request that Sarah Pomponi delete personal information about you. Before deleting information, Sarah Pomponi must be able to verify your identity. Sarah Pomponi will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where Sarah Pomponi is required or permitted to retain the information by law. For example, Sarah Pomponi cannot delete information about you while continuing to provide you with a service or where required to be retained.Sarah Pomponi does not discriminate against you if you choose to exercise these rights.

Submitting Privacy Requests

You can exercise your privacy rights by submitting requests to Sarah Pomponi to exercise those rights and by taking other steps that will limit how information about you is collected, used, and shared.Sarah Pomponi must verify your identity before fulfilling your personal information request. To verify your identity, Sarah Pomponi will collect information from you, including, to the extent applicable, your name, government identification number, date of birth, contact information, your account information, answers to security questions, or other personal identifying information. Sarah Pomponi will match this information against information previously collected about you to verify your identity and to respond to your request. Information collected for purposes of verifying your request will only be used for verification and to respond to your personal information request. If Sarah Pomponi is unable to verify your identity as part of your request, Sarah Pomponi will not be able to satisfy your request. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.

Linking to Third Parties

When you leave this Website and go to another linked website, Sarah Pomponi is not responsible for the content or availability of the linked website. Please be advised that if you enter into a transaction on the third-party website, Sarah Pomponi does not represent either the third party or you. Further, the privacy and security policies of the linked website may differ from those practiced by Sarah Pomponi.

Changes to this Policy

Sarah Pomponi reserves the right to change this Privacy Policy at any time in Sarah Pomponi’s sole discretion. If Sarah Pomponi makes changes, Sarah Pomponi will post the revised policy here, so that you can see what information Sarah Pomponi gathers, how Sarah Pomponi might use that information and in what circumstances Sarah Pomponi may disclose it. By continuing to use Sarah Pomponi’s services after notice is provided, you accept and agree to this Privacy Policy as modified.