Privacy Policy – Bigly Sales
Effective Date: July 21, 2022
Last Updated: February 27, 2023

Bigly Sales, Inc. (“Company,” “we,” “our,” or “us”) respects the privacy of users of our website, applications, and services (collectively, “Platform”). This Privacy Policy governs the use, collection, disclosure, and protection of personal information from you by the Company and its affiliates through your use of our Platform. It also informs you of the rights and choices you have with respect to your personal information, and how you can reach us to exercise your rights or ask questions.

Types Of Information Collected

The Company, and any third party we engage for the purpose of administering, operating, hosting, configuring, designing, maintaining, and providing internal support may collect information from the following two categories: (1) personal information that you voluntarily provide about yourself, and (2) usage information relating to your interactions with us and the Platform (including information that you submit or upload directly to the Platform). In some cases, it is an agent or vendor of ours that collects the information on our behalf. We may collect this information when you register for the Platform, request a demo through our Platform, sign up for our mailing list or other marketing materials, or interact with us for any other purpose.

Personal information we collect may include, among other things, the following categories:

• Personal and basic Identifiers: real name, alias, postal address, phone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name.
• Demographic Data: Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, veteran or military status, some of which are protected classifications under state and federal law.
• Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Device and online identifiers: internet protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers
• Internet or other similar network activity: Browsing history, search history, and information on consumer’s interaction with our website, application, or advertisement.
• Geolocation Data: Physical location or movements
• Professional or employment-related information: Current or past job history or performance evaluations.
• Sensitive Personal Information: Consumer’s precise geolocation, racial or ethnic origin, religious or philosophical beliefs

How We Use Personal Information

We may use the information we collect for various purposes, including the following:

• to communicate with you about your inquiries, including providing a demo or more information about our Platform and other services and products;
• to provide and improve our services, and to help provide new services, features, products, and opportunities to our customers;
• to improve our services and to develop new products, features, and technologies that benefit our users. For example, we use publicly available information to help train AI models and build products and features with AI capabilities;
• to operate, customize, and improve the Platform, including for analytics purposes, research, and development regarding how you interact with the Platform; customize marketing and advertisements shown to you;
• to send surveys, promotions, and marketing materials that may be of interest to you tailored to your interest;
• to comply with applicable laws and regulations and to maintain the security of our Platform. 

How We Share Personal Information

We may share the information we collect with other parties, including:

• Affiliates. We may share personal information that we collect through the Platform with affiliates or with any company that is directly or indirectly owned, controlled, or operated by Company so that we and they can communicate with you about products and services that we believe may be of interest to you. The use and further disclosure of the information collected on the Platform by our affiliated companies will be governed by this Privacy Policy.
• Service Providers. We have arrangements with third-party vendors, such as backend service providers, that assist us with the operation of the Platform or the services and features we offer through the Platform, including vendors that process personal information on our behalf. To protect your privacy, we do not authorize our vendors to retain, use, or disclose personal information we collect for any purpose other than to provide the services that they provide for us or our users.
• Your Consent or as Otherwise Disclosed. We may share information with your consent or as otherwise disclosed at the time of data collection or sharing. For example, our Platform may offer optional services or features, such as promotions, associated with unaffiliated third-party companies. If you choose to use these optional services or features, we may provide information to such third parties. We will not do so without telling you in advance, and you can avoid having us make such disclosures by choosing to opt out of using these services or features of the Platform.
• To Comply with Law. We may share information about our customers when release is required by a governmental agency, court, or other entity (e.g., to comply with legal process), or when appropriate to enforce our Terms of Use, or to protect the rights, property, or safety of visitors to our Platform, the public, our customers, or of Company.
• As Part of a Change in Corporate Control. In the event of a bankruptcy, merger, acquisition, transfer of control, or joint venture, information about our visitors would be among the transferred assets. We may also share information as part of administrative proceedings regarding the sale of our assets.
• In addition, we may use aggregated or de-identified information, such as anonymized analytics regarding user access to our Platform, and the activities and preferences of our customers, and disclose it to third parties without limitation.

Children’s Privacy

We do not knowingly collect personal information regarding any individuals under the age of 13. If we learn that we have unintentionally collected personal information regarding any individual younger than 13 years old, we will promptly delete that information.

Cookies

To help make our Platform more responsive to the needs of our visitors, we use a standard feature of browser software, called a “cookie,” to assign each visitor a unique, random numerical identification code that resides on their computer. The cookie doesn’t actually identify the visitor, just the device that a visitor uses to access our Platform. You have the ability to accept or decline cookies. 

We use cookies to track usage of the Platform and further personalize your experience when you are visiting the Platform. By tracking usage, we can determine what features of the Platform best serve our users. Overall, the use of cookies helps to give you a more personalized experience at the Platform. The information is used to keep our Platform relevant and convenient for you and to allow you to avoid retyping your login credentials each time you access the Platform.

We use the following types of cookies: 

• Essential Cookies are required to make our Site function properly and cannot be turned off in our systems. If you block these cookies, portions of our Platform may not function properly.
• Performance and Functional Cookies allow us to count visits and sources of traffic on our Platform so we can measure and improve performance and functionality. They help us know which pages of our Site are most and least popular and how visitors move around the Site.
• Targeted Advertising Cookies may be set through our Platform by our advertising partners. They may be used by advertising companies to build a profile of your interests and show you relevant advertisements on other websites. 
• Social Media Cookies allow you to share information using social media sharing buttons on social networks like Facebook, Pinterest, Instagram, or Twitter. This information may then be used by the social media network to deliver targeted advertising to you.

Managing Cookies

If you wish to opt out of allowing certain cookies, you may do so by changing your browser settings so that cookies from our website cannot be set. Please note that if you delete, block, or otherwise restrict cookies, or use a different computer or Internet browser, you will need to renew your cookie management choices.

Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647 (Chrome);

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

Please note that this Cookie policy does not apply to, and we are not responsible for, the privacy practices of third-party websites that may be linked to our websites.

Digital Advertising, Web Sessions Recording Technologies & Web Analytics

When you visit our website, we use site visit recordation technologies, to memorialize site visits, third-party cookies, beacons, tags, and scripts to help collect the categories of information described above and aggregated information from your internet browser such as your behavior on our website.  

We and third parties also use tools that enable us to track certain aspects of a user’s visit to our websites. These technologies help us better manage content on our websites by informing us what content is effective, how consumers engage with our websites, and how consumers arrive at and/or depart from our websites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that tracks usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers that are embedded in web pages and email messages that track whether a user views a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information if provided by the user.

We may use the following technologies across our websites:  

We also use Microsoft Clarity to monitor and improve our services. Microsoft Clarity is a website analytics service that we use to track how users interact with our website. The service collects data on user behavior, such as clicks, scrolls, and navigation. 

For more information about Microsoft Clarity’s policies and practices, please see Microsoft Clarity’s privacy policy at https://privacy.microsoft.com/en-us/privacystatement. You can deactivate Microsoft Clarity’s services by contacting us directly at [email protected]

We use Google Analytics, an independent 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 website. 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. For more information about Google’s policies and practices, please see Google’s privacy policy at https://www.google.com/intl/en/policies/privacy. You may opt out of the aggregation and analysis of data collected about you on our website by Google Analytics by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/. Please note that if you opt-out, analytics companies other than Google Analytics may continue to aggregate and analyze data collected about you on our website.

To better assess and optimize our marketing activities, we may use a tool called the “Metal Pixel” operated by Meta (formerly Facebook). Facebook is able to determine the visitors of our online offers as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Meta pixel to display our Facebook ads only to Facebook users who have shown an interest in our website or who have specific characteristics that we submit to Facebook. Meta pixel allows us to ensure that Facebook ads are in line with the potential interest of users. Meta pixel also allows us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad.

The Meta pixel may be directly integrated into our website by Facebook and can store a cookie on your device. If you then log in to Facebook or visit Facebook when you are logged in, your visit to our online offer will be noted in your profile. The data collected about you is anonymous for us, i. e. it does not allow us to draw conclusions about the identity of the users. However, the data is stored and processed by Facebook so that it can be linked to the respective user profile and used by Facebook as well as for its own market research and advertising purposes. If we transfer data to Facebook for comparison purposes, it is encrypted locally in the browser and only then sent to Facebook via a secure https connection. This is done with the sole purpose of matching the data encrypted by Facebook.

For more information about Facebook’s policies and practices, please see the Facebook Data Usage Policy at: https://www.facebook.com/policy.php. For specific information and details about the Facebook pixel and how it works, visit the Facebook Help Center at: https://www.facebook.com/business/help/651294705016616.

Your use of our website implies your consent to the use of Meta Pixel. You may manage your preferences or opt out of data collection through Metal Pixel by visiting and following the instructions on how to set up user-based advertising at: https://www.facebook.com/settings?tab=ads.

We use site visit recordation technology to memorialize site visits, including technology provided by third parties, including Active Prospect’s TrustedForm, as applicable. We use TrustedForm to independently document users’ consent to be contacted. We use TrustedForm to independently document users’ consent to be contacted. The TrustedForm Script is embedded on our website and collects the following information when you interact with the page(s) where the script is present: page URL, mouse movements and clicks, contact information inputted by the user, a snapshot of the page, including IP address of the user’s computer, time on the page, date and time that the TrustedForm Script was loaded, as well as the date and time of the various user interactions with the page, and HTTP headers from the user’s browser (“Data Collection Pages”). For more information about ActiveProspect’s data use and collection policies and practices, please review the ActiveProspect Privacy Policy, located at https://activeprospect.com/privacy-policy/. 

We reserve the right to remove or add new analytic technologies.

Web Beacons: Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as ‘clear gifs’). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. We may include web beacons in promotional email messages or Newsletters to determine whether messages have been opened and acted upon.

Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Platform and some of the electronic communications you receive from us. We keep this information for our internal use, and this information is not shared with others.

ChatBot Technology. 

We may also use third-party service providers to provide chat services for our clients to communicate with us regarding your account and other general questions you may have. As you navigate our Platform and use the chat systems with us, we attempt to protect your privacy to the maximum extent possible. However, some of the information that we receive through this Platform and your interactions with the chatbot system may be tracked, such as the date you communicated with us, the last day you contacted us, and other messages, comments, and conversations made through the chat messages. The chat system collects the information that you voluntarily type in the chatbot when you initiate a query through the chat system and respond to a query from the chat system. Additionally, when you are using our chatbot system, it collects interactions that you have made in the chatbot system while communicating with a customer service representative. This data is used to understand your preferences, provide personalized responses, and enhance the performance and functionality of the chatbot. We may retain this information for a reasonable period unless you request its deletion. You can maximize the benefits of your privacy partnership with us by making informed decisions about whether to share personally identifiable information with us through our Platform. Third-party chatbot systems may capture, record, or analyze your chatbot communications with us. 

Through our chatbot services, we may use AI technology (“Chatbot”) to power the chat functionality which is intended to provide immediate responses to your questions. While we have made every effort to ensure that the Chatbot provides accurate and up-to-date information, please understand that it may not be able to address more complex queries fully and sometimes, it might even give a completely wrong answer.

The information provided by the Chatbot should not be solely relied upon for making critical decisions or resolving complex issues. Users are responsible for verifying and cross-referencing the information provided and should exercise caution and judgment when relying on its responses.

Under no circumstances shall the Company be liable for any direct, indirect, special, incidental, or consequential damages arising out of or in connection with the use of the chatbots on its Platform. This includes, without limitation, any damage, loss, or injury caused by error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft or destruction, or unauthorized access to, alteration of, or use of the chatbot.

While we make efforts to ensure the availability and reliability of the chatbot, there may be instances where it is unavailable or experiences technical issues. The Company shall not be held responsible for any inconvenience or damages arising from such occurrences.

Information Security

The Company maintains reasonable safeguards to protect the security, integrity, and privacy of the information that you provide to us. However, no security system is impenetrable, and we cannot guarantee the security of the information we collect. Nor can we guarantee that the information you supply won’t be intercepted while being transmitted to us over the Internet.

Opting Out or Unsubscribe

Whether you submit any Personal Information to us is entirely up to you. You are under no obligation to provide Personal Information. However, in the event this information is essential for us to provide certain services to you, we will be unable to provide you with those services if you choose to withhold the requested information. We respect your privacy and ability to choose whether to share information with us and third parties. You may opt-out from receiving e-mail communications from us regarding marketing and promotion for new products and services by bit.ly/40OpG5V Similarly, if we ask a third-party company to send email offers regarding our products and services to customers, we will share with that company a list of email addresses collected from visitors of our Platform who have opted-out of our email program to ensure that their privacy preferences are honored. You may additionally opt out of both email and text message communications by sending your request to [[email protected]]. If you elect to unsubscribe, we will remove you from the relevant list within 10 business days.

If you remain an active registered user of our Platform following an opt-out request, we may still send emails containing important notices or updates to you regarding your current use of the Platform.

State Privacy Rights

California residents should refer to our California Privacy Notice for more information about our privacy practices and their California privacy rights.

Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: [email protected].

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at [email protected]

Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law. 

Privacy Notice for California Residents

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Bigly Sales Inc. Privacy Policy (the “Privacy Policy”) made available on the website located at www.BiglySales.com (the “Site”). The Site is owned and operated by Bigly Sales Inc. (“Company,” “we,” “us” or “our”). This Privacy Notice applies solely to residents of the State of California (“CA Users”). We adopt this Privacy Notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”). Any terms defined in the CCPA and/or CPRA have the same meaning when used in this Privacy Notice. CA Users with disabilities who wish to access this Privacy Notice in an alternative format can contact us by emailing us at: [email protected]

Categories of Information We Collect 

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”).  In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months: 

Personal information does not include: 

• Publicly available information from government records.
• Information that we believe has been lawfully made public by the consumer or from widely distributed media or from disclosure to a third party by the consumer where the consumer did not limit disclosure to a specific audience.
• De-identified or aggregated CA User information.
• Information excluded from the CCPA’s and CPRA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. 

We obtain the categories of personal information listed above from the following categories of sources: 

• Directly from our CA Users. For example, contact forms, benefits application forms, and other registration forms that our CA Users submit to us in connection with the products and/or services that are featured by and through the Site.
• Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them.
• Directly and indirectly from activity on the Site. This includes the type of browser that the CA User uses (e.g., Safari, Chrome, Internet Explorer), CA User’s IP address, the type of operating system used by the CA User (e.g., Windows or iOS), and the domain name of the CA User’s Internet Service Provider. In addition, we obtain certain Site usage details and analytics as the same are collected automatically by us and our third-party partners.
• When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts.
• From third parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third-party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data, and providing marketing analysis.

Retention of Personal Information and Sensitive Personal Information

We retain all categories of your personal information and sensitive personal information that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected personal and sensitive personal information including:

• Date of collection.
• Frequency of consumer interaction with us.
• Last interaction the consumer had with us.
• Whether the purpose of collection has been completed.

Use of Personal Information 

We may use or disclose the personal information that we collect for one or more of the following business purposes: 

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for products and/or services, we will use that information to process your request.
• To provide you with information, products, or services that you request from us.
• To create, maintain, customize, and secure your account with us.
• To provide you with e-mail, direct mail, and telemarketing messages concerning certain Company products and/or services, as well as third-party products and/or services, that we believe may be of interest to you.
• To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. 
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions.
• To improve the Site and better present its contents to you.
• For customer service purposes and to respond to inquiries from you.
• For testing, research, analysis, and product development.
• As necessary or appropriate to protect our rights, property, or safety, and that of our clients and/or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise outlined in the CCPA and/or CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice. 

Sharing Personal Information 

Subject to your right to opt out of such sharing/sale, we may share, rent, and/or sell your personal information: (a) with/to third parties for marketing purposes; and (b) for the other business purposes set forth above. 

When we disclose personal information to a third-party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that the third party both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, that we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months. 

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: 

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity. 

Category L Sensitive Personal Information (disclosed solely as required in connection with facilitating your application for SSDI benefits).

We disclose your personal information for a business purpose to the following categories of third parties: 

• Our affiliates (but not your Sensitive Personal Information).
• Service providers.
• Third parties who provide the products and/or services featured on the Site (but not your Sensitive Personal Information).
• Third parties who purchase and/or license your personal information for marketing purposes, including (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression, and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers (but not your Sensitive Personal Information). If a third-party purchaser of your personal information wants to resell it, that purchaser is required by law to provide you with explicit notice and an opportunity to opt out of further sales, unless the right to resell it was secured by us at the point of collection.
• Third parties to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you.

In the preceding twelve (12) months, we have sold the following categories of personal information to third parties: 

Category A Identifiers.
Category B California Customer Records personal information categories.
Category C Protected classification characteristics under California or federal law.
Category F Internet or other similar network activity. 

In the preceding twelve (12) months, we have sold the above-referenced categories of personal information (but not your Sensitive Personal Information, other than required in connection with facilitating your application for SSDI benefits) to third parties who purchase and/or license your personal information for marketing purposes, as well as the third parties who provide the products and/or services featured on the Site. 

Your Rights and Choices 

The CCPA and CPRA provide CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights and explains how to exercise those rights. 

Opt-Out from the Sale of Your Personal Information

You have the right to opt out of our sale of your personal information (including sensitive information) to third parties. To exercise any or all of these rights to limit our use of your personal information, please submit a verifiable User request to us by either: Clicking here or by emailing us at: [email protected]

We endeavor to act on all opt-out requests as soon as practicable but in all cases within ten (10) business days of the receipt of your request. 

Opt-Out from the Sharing of Your Personal Information

You have the right to opt out of our sharing your personal information with third parties.  To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either clicking here or by emailing us at: [email protected]

We endeavor to act on all opt-out requests as soon as practicable but in all cases within ten (10) business days of the receipt of your request.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category L (Sensitive Personal Information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Company.

You also have the right to opt out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law), and/or Category L (Sensitive Personal Information).  

To exercise your right to limit our use of your sensitive personal information and/or opt out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either Clicking here or by emailing us at: [email protected]

We endeavor to act on all such requests as soon as practicable but in all cases within ten (10) business days of the receipt of your request.

Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you: 

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we have shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Request Correction of Inaccurate Personal or Sensitive Personal Information

You have the right to request correction of inaccurate personal and/or sensitive personal information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate. 

Right to Request Deletion of Personal and/or Sensitive Personal Information

You have the right to request that we delete any of your personal information and/or sensitive information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, but only if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights 

To exercise your access, data portability, and/or deletion rights described above, please submit a verifiable CA User request to us by either Clicking here or by Emailing us at: [email protected]

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. 

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must: 

• Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor’s identity or authority to make the request. 

Response Timing and Format 

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

How to Submit an Appeal

You may appeal our decision with respect to a request you have submitted by going to our Internal Dispute Notice.

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA and/or CPRA rights. Unless permitted by the CCPA and/or CPRA, we will not: 

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; 
• Provide you with a different level or quality of goods or services; and/or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Browser “Do Not Track” Signals. Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the User’s browser notifies other websites that the User does not want her/his personal information and online behavior to be tracked and used, for example, for interest-based advertising.  As required by the California Online Privacy Protection Act (“CalOPPA”), we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a Site User has activated the “do-not-track” setting on her/his browser.

Colorado Consumer Privacy Notice Summary

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Bigly Sales Inc. Privacy Policy (the “Privacy Policy”) made available on the website located at www.BiglySales.com (the “Site”). The Site is owned and operated by Bigly Sales Inc. (“Company,” “we,” “us” or “our”). This Privacy Notice applies solely to residents of the State of Colorado (“CO Users”). We adopt this Privacy Notice in compliance with the Colorado Privacy Act (the “CPA”). Any terms defined in the CPA have the same meaning when used in this Privacy Notice. CO Users with disabilities who wish to access this Privacy Notice in an alternative format can contact us by emailing us at: [email protected]; calling us at: [insert phone]; or sending us U.S. Mail to: 11197 Blackhawk Blvd. 12:37 Davie, FL 33328. This Colorado Notice uses certain terms that have the meaning given to them in the Colorado Privacy Act (the “CPA”).

Collection, Use, and Sharing of Personal Data

We may collect, use, and share personal data as described in the chart below. For more information on the categories of personal data we collect, please see our Privacy Policy. 

We do not knowingly process personal data from children under the age of 13. We also do not engage in profiling in the furtherance of decisions that produce legal or similarly significant effects concerning consumers, as defined in the CPA.

Your Colorado Privacy Rights

If you are a Colorado consumer who interacts with us in an individual or household capacity (and not in a commercial or employment context), you may have the right to (1) request access to, correction, or deletion of your personal data; and (2) opt-out of the processing of your personal data for purposes of targeted advertising or the sale of your personal data. In addition, you may have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal data to another entity.

How to Submit a Request 

To request access to, correction, or deletion of your personal data, go to the footer of our website and select the “Request My Personal Information” link. To opt out of the processing of your personal data for purposes of targeted advertising or the sale of your personal data, go to the footer of our website or the settings section of our app and select the “My Privacy Choices” link.

To submit an opt-out request as an authorized agent on behalf of a consumer, please contact us by Clicking here or by emailing us at: [email protected]

If you submit a request through an authorized agent, we may ask for your written permission or a power of attorney. Where you provided your authorized agent with written permission, we may require that you also verify your identity.

Colorado residents should refer to our Colorado Privacy Notice for more information about our privacy practices and their Colorado privacy rights.

Your Connecticut Privacy Rights

If you are a Connecticut resident, you have the following rights under applicable Connecticut law in relation to your personal information, subject to certain exceptions: 

• Right to Know and Access. You have the right to, up to twice in a 12-month period, request what personal data we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request under certain circumstances that we delete your personal data.
• Right to Opt-Out. You have the right to opt out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects.
• Right to Correct. You have the right to request the correction of your inaccurate personal data.
• Right to Data Portability. When accessing your data, you have a right to obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business.
• Right to Provide Affirmative Consent. We cannot process your sensitive data or use your personal data for certain purposes without your affirmative consent.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment for the exercise of the privacy rights described above.

Connecticut residents can exercise the following rights by going to the footer of our website and selecting the “Your Privacy Choices” link:

• Request to Access My Personal Information
• Delete My Personal Information
• Correct My Personal Information
• Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising
• Opt Out of the Sale of My Personal Information

If we decline to take action on one of your rights as a Connecticut resident, you can submit an appeal by emailing us at [email protected]

Your Nevada Privacy Rights

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about the Nevada State residents to any third-party data broker(s). Covered information includes a consumer’s name, postal and email address, telephone number, and Social Security Number, and includes the Information described below in the “Personal Information that We Collect” section.

If you are a Nevada State resident and you wish to exercise your right to request that we stop the selling of your Information to third-party data brokers, please e-mail us at: [email protected]

In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the website that you visited and the email address you registered with. Please allow thirty (30) days for a response.

Your Utah Privacy Rights

If you are a Utah resident, you have the following rights under applicable Utah law in relation to your personal information, subject to certain exceptions: 

• Right to Know and Access. You have the right to, up to twice in a 12-month period, request what personal data we collect, use, disclose, and/or sell, as applicable;
• Right to Delete. You have the right to request under certain circumstances that we delete your personal data.
• Right to Opt-Out. You have the right to opt out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects.
• Right to Data Portability and Right to Provide a Copy. When accessing your data, you have a right to obtain a copy of that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business. 
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment for the exercise of the privacy rights described above.

Utah residents can exercise the following rights by going to the footer of our website or settings section of our app and selecting the “Your Privacy Choices” link:

• Request to Access My Personal Information
• Delete My Personal Information
• Correct My Personal Information
• Opt-Out of the Processing of My Personal Information for Purposes of Targeted Advertising
• Opt-Out of the Sale of My Personal Information

If we decline to take action on one of your rights as a Utah resident, you can submit an appeal by emailing us at [email protected]

Your Virginia Privacy Rights

If you are a Virginia resident, you have the following rights under applicable Virginia law in relation to your personal information, subject to certain exceptions: 

• Right to Know and Access. You have the right to, up to twice in a 12-month period, request what personal data we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request under certain circumstances that we delete your personal data.
• Right to Opt-Out. You have the right to opt out of targeted advertising, our sale of your personal data, and profiling decisions that could produce legal or similarly significant effects.
• Right to Correct. You have the right to request the correction of your inaccurate personal data.
• Right to Data Portability. When accessing your data, you have a right to obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business.
• Right to Provide Affirmative Consent. We cannot process your sensitive data or use your personal data for certain purposes without your affirmative consent.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment for the exercise of the privacy rights described above.

Virginia residents can exercise the following rights by going to the footer of our website or settings section of our app and selecting the “Your Privacy Choices” link:

• Request to Access My Personal Information
• Delete My Personal Information
• Correct My Personal Information
• Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising
• Opt Out of the Sale of My Personal Information

If we decline to take action on one of your rights as a Virginia resident, you can submit an appeal by emailing us at [email protected]

International Visitors

This section applies to those that use our Software from the European Economic Area (EEA), Switzerland, or the United Kingdom (UK).

We process your personal data for the following purposes:

When it is necessary for the performance of a contract to which you are a party, such as to provide services to you that you have purchased;

Where it is necessary, for purposes based on our legitimate interests, to communicate with you about the Company and our provides and services, to improve our client relationship and our products and services, and to ensure the correct use and proper functioning of the Platform;

Where required by law, such as in response to requests by government or law enforcement authorities conducting an investigation; and

We may also process personal data with your consent, for purposes explained at the time of collection.

Please be aware that the personal data we collect may be transferred to and maintained on servers or databases located outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location.

You have a right to the following:

To request access to the personal data we hold about you;

To request that we rectify or erase your personal data;

To request that we restrict or block the processing of your personal data;

Under certain circumstances, to receive personal data about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal data directly to another, i.e., a right to data portability; and

Where we previously obtained your consent, to withdraw consent to processing your personal data.

To exercise these rights, contact us at [email protected] using the “Contact Us” section below. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.

The personal data that you provide through our Platform may be stored on servers in the U.S. and supported from the U.S. We may also transfer personal data about you (whether collected online or offline) to our legal entities and affiliates and other service providers who perform functions on our behalf which are outside of the EEA, Switzerland, and the UK. This information may be stored and processed in those countries which may have different data protection standards to those which apply in your country of residence. Where personal data is transferred from the EEA, Switzerland, or the UK to the United States, we will take steps to ensure that your information is adequately protected through the use of approved standard contractual clauses or other approved safeguards.

We will process and retain personal data for a period of time based on the following criteria:

As long as necessary to fulfill the purposes outlined in this Policy;

In accordance with any applicable legal requirements; or

Pursuant to your request for deletion.

Personal data not subject to a statutory retention period is retained for at least two years and then archived if it is no longer necessary for any lawful purpose.

Contact Us

If you have any questions or comments about our Privacy Policy, please contact us at [email protected].

Changes to the Privacy Policy

We may make changes to this Privacy Policy by posting an updated version to this location (and/or any other notification method specifically required by applicable law). Any such changes will be promptly posted on this page with “Last Updated” posted at the beginning of this Privacy Policy and will become effective immediately upon posting. We encourage you to visit this page periodically to learn of any updates.