Privacy Policy
Last Updated Date: August 6, 2024
Version 3.0
Introduction and Scope
GOLO, LLC ("GOLO", "we", "us" or "our") respects the privacy of our visitors, users, customers, and members (referred to as "you" or "your"). This privacy policy ("Privacy Policy") describes the types of information we collect about you, how it is shared or otherwise used, your rights with regard to your information, and the measures we take to protect your information. This Privacy Policy applies to personal information collected by or on behalf of GOLO, including information provided when you purchase or use our products (by any method) ("Products") or use our services ("Services"), or information collected through our golo.com website ("Website"); our mobile app ("Mobile App"); by email, phone, or other offline method; or anywhere else we display this Privacy Policy (collectively, the Website, Mobile App, and other data collection points are referred to herein as the "Platform"). This Privacy Policy applies to you as applicable to the category to which you belong.
For California residents who are applying for an employment or independent contractor position with GOLO, please see our separate Privacy Notice for California Job Candidates and Independent Contractors, available here (and which is incorporated by reference herein and as amended from time to time as posted on our Website).
By visiting or using our Platform, or by purchasing or using our Products or Services, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, please do not use our Platform, Products or Services. Your use of the Platform and our Products and Services is at all times subject to our Terms of Use (available on our Terms of Use and as updated from time to time (the "Terms")), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.
Personal Information We Collect and How We Collect It
Personal Information is information that directly or indirectly identifies you or can be used to identify you as an individual. Personal Information does not include information publicly available from government records or information excluded by applicable law. Personal Information also does not include information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so that the data can no longer be attributed to a specific individual in accordance with applicable laws ("De-Identified Personal Information").
The following are the categories of Personal Information we collect about you and how we collect it:
Information You Provide Us. We collect certain Personal Information you choose to provide when you visit or use the Platform, including via phone calls, texts, emails, mail, and user content posts. For example:
- Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Website, products, or Services, or otherwise communicating with us.
- You may share your name, email, address, and other contact information when you establish an account with us, as well as payment or billing information when you complete a transaction.
- Information you provide when you email, call, use our customer services or support features, or otherwise contact us.
- Your responses to surveys that we or our service providers might ask you to complete for research purposes or answers to questionnaires on our Website to help us customize recommendations to you.
- Information you share to participate in our loyalty/rewards programs.
- Feedback, photos or other testimonial or review information you choose to share.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, and other online activities. The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, and/or IP address. Each of these is discussed below.
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (e.g., Internet Explorer, Firefox, Safari, Google Chrome, etc.). We also use cookies to implement tracking technology on our Platform. This allows us to display advertising that is tailored to you on our Platform which parts of our content interest you the most and which Service categories you request. Some of our service providers are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider. It is possible that you will also come across third-party cookies on some pages of sites that are not under our control, please refer to the section below on Links to Third-Party Sites for information on those activities. We may also use cookies to track whether you open emails we send to you.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Pixel Tracking. In addition to using Cookies, the Website may employ "pixel tracking", a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A "pixel tag" is an invisible tag placed on certain pages of websites that is used to track an individual user's activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.
GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
Log Files. Our servers (or those of our service providers) may automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol ("IP") address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.
The information we collect using online tracking technologies may include:
- Usage Data: Details of your visits to our Website or use of the Mobile App, including, but not limited to, website traffic data, logs, and other communication data and the resources that you access and use on the Website or Mobile App.
- Device Information: Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website or using the Mobile App, and the pages you viewed while on our Website.
- Location Data: We collect and use IP address and mailing address for marketing purposes, e.g., to set parameters for different types of communications based on geographic information (such as zip code). Our marketing or advertising service providers may use location data (via IP address) to automatically display advertising on your device based on where you are at a point in time in relation to a particular location (for example, a shopping mall). We do not store your momentary geolocation data (i.e., time or precise place), though various third parties such as Google or Waze may for their own purposes, if you have given them permission to do so.
- Behavioral Tracking: We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.
- Keystrokes: We or our service providers may keep track of and/or collect the keystrokes, mouse clicks, and cursor movements of Website visitors and Mobile App users before purchase of a Product or Service from our Website (and before we have any email address or other information about you (other than IP address) which would specifically identify you). If you sign up to receive our emails (e.g., through a popup box that appears) we then do have the ability going forward to associate the keystroke and cursor information with the email address you provide. We use this information for the purpose of improving our Website, Mobile App, Products, and Services, and to improve our customers' user experience.
- Analytics Data: The Site also uses analytics tools such as Google Analytics, a web analytics service provided by Google, Inc. that uses cookies to help us analyze how users navigate the Site. The information generated by this tool (including IP address) will be transmitted to and stored by Google in aggregate form and used to evaluate use of the Site, compile reports on Site activity and other services relating to Site usage. You can learn more about Google Analytics and how to opt out here: https://tools.google.com/dlpage/gaoptout.
Information We Collect from Third Parties. We may collect information that others provide about you when you use the Platform, or obtain information from other sources and combine that with information we collect through the Platform. For example:
- Third Party Services. If you link, connect, or login to your account with a third-party social media service (e.g., Facebook, Google, Instagram, Yelp, etc.), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
- Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Platform through partnerships, or about your experiences and interactions from our partner ad networks.
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Website or Mobile App are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or Mobile App. The information that first party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content about our products.
Managing and Opting Out of Online Tracking
You can adjust the settings on your browser to block or opt out of certain cookies and other online tracking, including those used for targeted or cross-contextual advertising. To manage your settings, visit the "Your Privacy Choices" link at the footer of our Website or Platform and select the "Do Not Sell or Share My Personal Information" button to adjust the online tracking preferences. You can also find out more about cookies and how to manage them by visiting www.AboutCookies.org.
Do-Not-Track Signals
Some browsers have a Do-Not-Track ("DNT") feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity online tracking technologies. While we continue to evaluate this evolving technology, our Website does not currently respond to browser-based DNT signals.
How We Use Your Information
We may use your Personal Information for one or more of the following purposes:
- To provide the Platform or our Products or Services to you and related customer service.
- To provide you with information about our Products or Services or promotions that may be of interest to you, send you text messages (based on your indicated preferences), respond to your questions or otherwise communicate with you
- To notify you about information regarding or changes to the Platform, our policies, terms, or any Products or Services we offer or provide, or regarding your account.
- To enhance and improve the Platform or our Products and Services, for example, by performing internal research, analyzing user trends, product development, or measuring demographics and interests.
- Register you as an account holder and provide our loyalty program and other Services.
- Comply with law and law enforcement requirements or to protect the legal rights or health or safety of our customers, employees or others.
How We Disclose Your Personal Information
For the purposes noted above, we may disclose your Personal Information, in whole or in part, with:
- Service providers that help us with business activities, marketing, order fulfillment, and technology services or other activities necessary to operate our business or to offer special events or programs.
- A successor entity, to which we reserve the right to sell, rent, disclosure or transfer your Personal Information, in the event of a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate changes to our company.
- Other third parties such as necessary to protect our legal interests, rights or property; to comply with or satisfy any law, regulation, governmental request, or other legal requirements; to avoid liability; or to protect our rights or property or the health or safety of others.
International Users
GOLO, LLC is located in and operates in the United States. Our Services, Products and the Platform are not targeted at individuals outside the United States. If you are visiting the platform from outside the United States or otherwise provide us with Personal Information, please note that your information will be accessed, transferred, stored and processed by GOLO in the United States or outside the jurisdiction where you are located, where the data protection laws may differ from the country where you are located. By doing business with or interacting with the Platform, you acknowledge and agree to the transfer of your Personal Information to the United States and understand that such information will be stored and processed in accordance with this Privacy Policy and the laws of the United States.
Security
We have implemented measures designed to secure your Personal Information from accidental loss or unauthorized access, use, alteration, and disclosure. However, because no measure is ever 100% effective when transmitting information over the Internet, we do not guarantee that your information will be secure from theft, loss or unauthorized access.
Children's Data
Neither the Platform nor our Products or Services are targeted to or intended for persons under age 18. We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. In the event that we learn that we have collected Personal Information from a child under age 18, we will use commercially reasonable efforts to delete that information from our database.
Your Rights and Choices
You can choose not to give us your Personal Information but in some cases, we will not be able to provide our Products or Services or respond to your questions or requests without certain information. In addition to the cookie preferences noted above, you have the following choices with regard to your information and engagement with the Platform:
- Updates to Your Information. Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Products, Website, Mobile App, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us using the contact information at the bottom of this Privacy Policy.
- Communication Preferences. You can adjust your communication preferences with us at any time by contacting us using the contact information at the bottom of this Privacy Policy. You can also request to be removed from marketing emails by clicking the "unsubscribe" link in our email messages. You can opt out of text messages by replying "STOP" to any mobile message from us or as further described in our SMS Terms of Service page here.
Links to Third-Party Sites
The Platform may include links to third-party websites we think may be of interest to you, such as Facebook, LinkedIn, X, Instagram or other platforms. Please note that these websites are independent from the Platform and we are not responsible for the content or privacy practices of such other sites or platforms. Your use of such third-party sites will be subject to the third-party's privacy policies.
Changes to Our Privacy Policy
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Any updates to this Privacy Policy will be posted on the Platform and we will indicate the last updated date of the changes at the top of the Privacy Policy. Your continued use of the Platform means you accept those changes as of the last updated date.
Contact Information
If you have any questions about this Privacy Policy, our privacy practices, or for any other purposes, please contact us: by email at privacy@golo.com; or by phone at 1-800-503-2390.
If you are trying to reach customer service regarding an order, please contact at support@golo.com or call 1-800-730-4656.
State-Specific Notices and Disclosures
Depending on your state of residence, you may have additional rights or choices as further described in the state-specific notices below.
California Privacy Notice
This California Privacy Notice section ("CA Notice") describes how we collect, use, disclose and otherwise process personal information of California residents within the scope of the California Privacy Protection Act of 2018, as amended by the California Privacy Rights Act of 2020 ("CCPA").
Unless otherwise defined in this CA Notice, all terms defined in this Privacy Policy and all other terms defined in the CCPA have the same meaning when used in this CA Notice.
This CA Notice supplements the information contained elsewhere in this Privacy Policy and applies to personal information of residents of California ("consumers" or "you"), collected, used, disclosed, or otherwise processed by or on behalf of GOLO.
Personal Information
In this CA Notice, "personal information" means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household in accordance with the CCPA. Personal information does not include: a) de-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you or a particular household; or b) publicly available information from government records.
We process the categories of personal information further described in the "Personal Information We Collect and How We Collect It" section of this Privacy Policy and as shown in the table below.
Personal Information Recipients
As described further in the "How We Disclose Your Personal Information" section of this Privacy Policy, we share personal information with service providers or processors that help us operate our Platform and Services and provide our Products. We may also share personal information with a variety of third parties, including for marketing purposes; if we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented. For purposes of this CA Notice, when we use the term "third party" we mean entities that are not a GOLO entity or processors providing services on behalf of GOLO and that are not entities with whom you interact with directly.
In the last 12 months, we have collected the categories of personal information as noted in the table below and disclosed it, for business purposes, to the categories of recipients listed below. The table also indicates when we sold or shared the personal information to third parties in the last 12 months or processed such information for targeted advertising.
Category of Personal Information |
Categories of Recipients to Whom Personal Information is Disclosed for Business Purposes |
Sold or shared with Third Parties for Targeted Advertising |
Categories of Third Parties to Whom Personal Information Is Sold or Shared for Targeted Advertising |
---|---|---|---|
Identifiers, such as name, email address and other information. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate and payment information. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Protected Classification Characteristics such as ethnicity and gender. |
Service providers, including those that assist with employment screening and operational support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Commercial Information, such as shopping history and other information relating to your hobbies, interests and consumer purchasing behavior. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Biometric Information, such as behavioral characteristics used to identify you; imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings from which an identifier such as a faceprint can be extracted; keystroke patterns or rhythms; gait patterns or rhythms; and sleep, health or other exercise data that contains identifying information. |
N/A |
N/A |
N/A |
Internet/Network Information, such as browsing history, search history, and information regarding your interaction with an internet website application or advertisement, such as IP address, device information, and log and analytics data. |
Service providers, including those that assist with order fulfillment, loyalty programs, marketing, advertising, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Geolocation Data, such as location information from your device or estimated based on your IP address. |
Service providers, including those that assist with order fulfillment, loyalty programs, marketing, advertising, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Sensory Information, such as recordings of phone calls between you and us, where permitted by law. |
Service providers, including those that assist with order fulfillment, customer service, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Other Personal Information, such as information you post on our Platforms or on social media pages, and information you submit to us. |
Service providers, including those that assist with order fulfillment, loyalty programs, marketing, advertising, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Inferences, such as shopping history, products and services purchased, obtained or considered or other purchasing or consuming histories or tendencies. |
Service providers, including those that assist with order fulfillment, loyalty programs, marketing, advertising, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Sensitive Personal Information, such as: Social Security number, driver's license number or other state-issued ID; account log-in credentials; financial account, debit or credit card number with any required PIN or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs; content of mail, email or text messages where we are not the recipient; genetic data; information concerning a consumer's health, sex life or sexual orientation. |
Service providers, including those that assist with order fulfillment and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
We do not use or disclose Sensitive Personal Information outside of the permitted purposes set forth under Section 7027(m) of the CCPA Regulations.
Sources of Personal Information
As described in the "Personal Information We Collect and How We Collect It" section of this Privacy Policy, we collect personal information directly from you when you provide it to us, automatically using cookies and other online tracking technologies, from categories of third parties, and by combining personal information we may otherwise obtain.
Purposes for Processing
We process personal information for different purposes, depending on how you interact with the Platform, Products, and Services. We collect, sell, share or disclose personal information about you for the business and commercial purposes described in the "How We Use Your Information" section of this Privacy Policy.
Retention
The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletion you might request, as well as our need to address our legal obligations or rights.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information that GOLO or our processors have collected (subject to certain limitations at law):
Right to Know (Categories) |
The right to request the following information relating to the personal information we have collected about you and disclosed about you:
|
---|---|
Right to Access (Right to Know Specific Pieces of Information) / Portability |
The right to access and obtain a copy of the specific pieces of personal information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible. |
Right to Correct |
The right to request that we correct your inaccurate personal information maintained by us. |
Right to Request Deletion |
The right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions under law. |
Right to Opt Out of Data Sales or Sharing |
The right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting or cross-contextual advertising. |
"Shine the Light" Law |
As provided by California Civil Code § 1798.83, California residents that have an established business relationship with us can request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures. |
How to Exercise Your California Privacy Rights
We will need to verify your identity and confirm you are a resident of California before processing most requests, which may require us to request additional personal information from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of information you provide us to the information we maintain about you in our systems. We will use the personal information provided in connection with a request as needed to review and comply with the request. If you do not provide the necessary information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of a California resident, then we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. Please see the "Authorized Agents" section below for more information.
We do not discriminate against you for requesting any of the rights noted above. In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
To Exercise Your Rights to Know, Access, Correct, Delete and/or "Shine the Light"
Please submit a request by filling out our Privacy Rights Request form or by calling 1-800-503-2390.
To Exercise Your Right to Opt Out of Personal Information Sales or Sharing
To exercise your right to opt-out of personal information sales or sharing, please submit a request by clicking here or by clicking the "Your Privacy Choices" link on our Platform then select the "Do Not Sell or Share My Personal Information" button.
Once you make an opt-out request, you may change your mind and opt back into personal information sales at any time by contacting us at privacy@golo.com.
Personal Information of Children Under Age 16
We do not process personal information of consumers we know to be less than 16 years of age.
Authorized Agents
In certain circumstances, you are permitted to use an "authorized agent" to submit CCPA requests on your behalf. We may verify the authorized agent's authority to act on your behalf as follows:
- For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Notice, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
- For requests to opt-out of personal information "sales" or "sharing," we may ask you to provide a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Financial Incentives
In some cases, we may offer you financial incentives as permitted by law in exchange for the collection, retention, or use of certain personal information about you. Each financial incentive related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to us. When applicable, we will provide information about the specific terms of the financial incentive and your rights on the webpage or form where the financial incentive is made available.
Colorado Privacy Notice
This Colorado Privacy Notice section ("CO Notice") describes how we collect, use, disclose and otherwise processes personal data of Colorado residents within the scope of the Colorado Privacy Act, including its implementing regulations ("CPA").
Unless otherwise defined in this CO Notice, all terms defined in this Privacy Policy and all other terms defined in the CPA have the same meaning when used in this CO Notice.
This CO Notice supplements the information contained elsewhere in this Privacy Policy and applies to personal data of residents of Colorado ("consumers" or "you"), collected, used, disclosed, or otherwise processed by or on behalf of GOLO.
Personal Data
In this CO Notice, "personal data" means information that is linked or reasonably linkable to an individual who can be readily identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, specific geolocation data, or an online identifier. Personal data does not include: a) de-identified data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual, or a device linked to such an individual; b) publicly available information that is lawfully made available from federal, state, or local government records and that we have a reasonable basis to believe a consumer has lawfully made available to the general public through widely distributed media without restrictions; or c) information about an individual acting in a commercial or employment context, as a job applicant, or as a beneficiary of someone acting in an employment context.
We process the categories of personal data further described in the "Personal Information We Collect and How We Collect It" section of this Privacy Policy and as shown in the table below.
Personal Data Recipients
As described further in the "How We Disclose Your Personal Information" section of this Privacy Policy, we share personal data with service providers or processors that help us operate our Platform and Services and provide our Products. We may also share personal data with a variety of third parties, including for marketing purposes; if we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented. For purposes of this CO Notice, when we use the term "third party" we mean entities that are not a GOLO entity or processors providing services on behalf of GOLO and that are not entities with whom you interact with directly.
We have collected the categories of personal data as noted in the table below and disclosed it to the categories of third parties listed below. The table also indicates when we sold the personal data to third parties or processed such information for targeted advertising.
Category of Personal Data |
Categories of Recipients to Whom Personal Information is Disclosed for Business Purposes |
Sold or shared with Third Parties for Targeted Advertising |
Categories of Third Parties to Whom Personal Data Is Sold or Shared for Targeted Advertising |
---|---|---|---|
Identifiers, such as name, email address and other information. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Protected Classification Characteristics such as ethnicity and gender. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Commercial Information, such as shopping history and other information relating to your hobbies, interests and shopping behavior. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Biometric Identifiers, such as biological, physical, or behavioral characteristics used to identify you; scans or records of eye retinas or irises; fingerprint; a voiceprint; facial mapping; facial geometry; facial templates; other unique biological, physical, or behavioral patterns or characteristics. |
N/A |
N/A |
N/A |
Internet/Network Information, such as browsing history, search history, and information regarding your interaction with an internet website application or advertisement, such as IP address, device information, and log and analytics data. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Geolocation Data, such as location information from your device or estimated based on your IP address. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Sensory Information, such as recordings of phone calls between you and us, where permitted by law. |
Service providers, including those that assist with order fulfillment, customer service, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Other Personal Data, such as information you post on our Platforms or on social media pages, and information you submit to us. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Profile Data, such as information generated by processing personal data to evaluate, analyze or predict your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Sensitive Data, such as: personal data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life or sexual orientation, citizenship or citizenship status, genetic or biometric data that may be processed for the purpose of uniquely identifying an individual; or personal data from a known child (under age 13). |
Service providers, including those that assist with order fulfillment and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
We sell personal data and process it for targeted advertising purposes, which means we display advertisements to you based on information we obtain about you through nonaffiliated websites, applications or online services to predict your interests or preferences. We sell or share your personal data for the purposes further described in the "How We Disclose Your Personal Information" section of this Privacy Policy. Please see your rights to opt out from these activities listed in the "How to Exercise Your Colorado Privacy Rights" section below.
Purpose for Processing
We process personal data for different purposes, depending on how you interact with the Platform, Products, and Services. We process personal data about you for the purposes described in the "How We Use Your Information" section of this Privacy Policy.
Your Colorado Privacy Rights
As a Colorado resident, you may be able to exercise the following rights in relation to the personal data that GOLO or our processors have collected (subject to certain limitations at law):
Right to Know |
The right to confirm whether or not we are processing your personal data. |
---|---|
Right to Access / Data Portability |
The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible. |
Right to Correct |
The right to request us to correct inaccuracies in the personal data we maintain about you. |
Right to Request Deletion |
The right to request the deletion of personal data we have collected from or about you, subject to certain exceptions. |
Right to Opt Out |
The right to direct us not to process your personal data for certain types of targeted advertising, to sell your personal data, or to process your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects on you. |
Right to Appeal |
The right to submit an appeal if your request is denied. |
How to Exercise Your Colorado Privacy Rights
We will need to verify your identity and confirm you are a resident of Colorado before processing most requests, which may require us to request additional personal data from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of information you provide us to the information we maintain about you in our systems. We will use the personal data provided in connection with a request as needed to review and comply with the request. If you do not provide the necessary information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of a Colorado resident (including a minor child), then we will also need sufficient information to verify that the individual is the person about whom we collected personal data and that you are authorized to submit the request on their behalf.
We do not discriminate against you for requesting any of the rights noted above. In certain circumstances, we may decline a request to exercise the rights described above.
To Exercise Your Rights to Know, Access / Data Portability, Correct, or Delete
Please submit a request by filling out our Privacy Rights Request form or by calling 1-800-503-2390.
To Exercise Your Right to Appeal
If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at privacy@golo.com.
To Exercise Your Right to Opt Out of Targeted Advertising, Sales, or Profiling
To exercise your right to opt-out of targeted advertising, personal information sales or profiling, please submit a request by clicking here or by clicking the "Your Privacy Choices" link on our Platform then select the "Do Not Sell or Share My Personal Information" button.
Once you make an opt-out request, you may change your mind and opt back into personal data sales at any time by contacting us at privacy@golo.com.
Sensitive Data and Personal Data of Children Under Age 13
When required by applicable law, we will only process your sensitive data if we obtain your consent. We do not process personal data of consumers we know to be less than 13 years of age and will not do so unless we receive affirmative authorization from the parent or guardian.
Connecticut Privacy Notice
This Connecticut Privacy Notice section ("CT Notice") describes how we collect, use, disclose and otherwise processes personal data of Connecticut residents within the scope of the Connecticut's Act Concerning Personal Data Privacy and Online Monitoring ("CTPA").
Unless otherwise defined in this CT Notice, all terms defined in this Privacy Policy and all other terms defined in the CTPA have the same meaning when used in this CT Notice.
This CT Notice supplements the information contained elsewhere in this Privacy Policy and applies to personal data of residents of Connecticut ("consumers" or "you"), collected, used, disclosed, or otherwise processed by or on behalf of GOLO.
Personal Data
In this CT Notice, "personal data" means information that is linked or reasonably linkable to an individual who can be readily identified, directly or indirectly. Personal data does not include: a) de-identified data that cannot reasonably be used infer information about, or otherwise be linked to, an identified or identifiable individual, or a device linked to such an individual; b) publicly available information that is lawfully made available from federal, state, or local government records and that we have a reasonable basis to believe a consumer has lawfully made available to the general public; or c) information about an individual acting in a commercial or employment context or as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, nonprofit or government agency whose communications or transactions with the controller occur solely within the context of that individual's role with the company, partnership, sole proprietorship, nonprofit or government agency.
We process the categories of personal data further described in the "Personal Information We Collect and How We Collect It" section of this Privacy Policy and as shown in the table below.
Personal Data Recipients
As described further in the "How We Disclose Your Personal Information" section of this Privacy Policy, we share personal data with service providers or processors that help us operate our Platform and Services and provide our Products. We may also share personal data with a variety of third parties, including for marketing purposes; if we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.
For purposes of this CT Notice, when we use the term "third party" we mean entities that are not a GOLO entity or processors providing services on behalf of GOLO and that are not entities with whom you interact with directly.
We have collected the categories of personal data as noted in the table below and disclosed it to the categories of third parties listed below. The table also indicates when we sold the personal data to third parties or processed such information for targeted advertising.
Category of Personal Data |
Categories of Recipients to Whom Personal Information is Disclosed for Business Purposes |
Sold or shared with Third Parties for Targeted Advertising |
Categories of Third Parties to Whom Personal Data Is Sold or Shared for Targeted Advertising |
---|---|---|---|
Identifiers, such as name, email address and other information. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Protected Classification Characteristics such as ethnicity and gender. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Commercial Information, such as shopping history and other information relating to your hobbies, interests and shopping behavior. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Biometric Data, such as biological characteristics used to identify you; fingerprint, a voiceprint, eye retinas, irises or other unique biological patterns or characteristics that are used to identify you. |
N/A |
N/A |
N/A |
Internet/Network Information, such as browsing history, search history, and information regarding your interaction with an internet website application or advertisement, such as IP address, device information, and log and analytics data. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Geolocation Data, such as location information from your device or estimated based on your IP address. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Sensory Information, such as recordings of phone calls between you and us, where permitted by law. |
Service providers, including those that assist with order fulfillment, customer service, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Other Personal Data, such as information you post on our Platforms or on social media pages, and information you submit to us. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Profile Data, such as information generated by processing personal data to evaluate, analyze or predict your economic situation, health, personal preferences, interests, reliability, behavior, location or movements. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising and marketing companies; data aggregators; data analytics providers |
Sensitive Data, such as: personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life, sexual orientation, citizenship or immigration status, genetic or biometric data that may be processed for the purpose of uniquely identifying an individual; personal data from a known child (under age 13), or precise geolocation data. |
Service providers, including those that assist with order fulfillment and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
We sell personal data and process it for targeted advertising purposes, which means we display advertisements to you based on information we obtain about you through nonaffiliated websites, applications, or online services to predict your interests or preferences. We sell or share your personal data for the purposes further described in the "How We Disclose Your Personal Information" section of this Privacy Policy. Please see your rights to opt out from these activities listed in the "How to Exercise Your Connecticut Privacy Rights" section below.
Purpose for Processing
We process personal data for different purposes, depending on how you interact with the Platform, Products, and Services. We process personal data about you for the purposes described in the "How We Use Your Information" section of this Privacy Policy.
Your Connecticut Privacy Rights
As a Connecticut resident, you may be able to exercise the following rights in relation to the personal data that GOLO or our processors have collected (subject to certain limitations at law):
Right to Know |
The right to confirm whether or not we are processing your personal data. |
---|---|
Right to Access / Data Portability |
The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible. |
Right to Correct |
The right to request us to correct inaccuracies in the personal data we maintain about you. |
Right to Request Deletion |
The right to request the deletion of personal data we have collected from or about you, subject to certain exceptions. |
Right to Opt Out |
The right to direct us not to process your personal data for certain types of targeted advertising, to sell your personal data, or to process your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects on you. |
Right to Appeal |
The right to submit an appeal if your request is denied. |
How to Exercise Your Connecticut Privacy Rights
We will need to verify your identity and confirm you are a resident of Connecticut before processing most requests, which may require us to request additional personal data from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of information you provide us to the information we maintain about you in our systems. We will use the personal data provided in connection with a request as needed to review and comply with the request. If you do not provide the necessary information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of a Connecticut resident (including a minor child), then we will also need sufficient information to verify that the individual is the person about whom we collected personal data and that you are authorized to submit the request on their behalf.
We do not discriminate against you for requesting any of the rights noted above. In certain circumstances, we may decline a request to exercise the rights described above.
To Exercise Your Rights to Know, Access / Data Portability, Correct, or Delete
Please submit a request by filling out our Privacy Rights Request form or by calling 1-800-503-2390.
To Exercise Your Right to Appeal
If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at privacy@golo.com.
To Exercise Your Right to Opt Out of Targeted Advertising, Sales, or Profiling
To exercise your right to opt-out of targeted advertising, personal information sales or profiling, please submit a request by clicking here or by clicking the "Your Privacy Choices" link on our Platform then select the "Do Not Sell or Share My Personal Information" button.
Once you make an opt-out request, you may change your mind and opt back into personal data sales at any time by contacting us at privacy@golo.com.
Sensitive Data and Personal Data of Children Under Age 13
When required by applicable law, we will only process your sensitive data if we obtain your consent. We do not process personal data of consumers we know to be less than 13 years of age and will not do so unless we receive affirmative authorization from the parent or guardian.
Virginia and Utah Privacy Notice
This Virginia and Utah Privacy Notice section ("VA/UT Notice") describes how we collect, use, disclose and otherwise processes personal data of Virginia residents within the scope of the Virginia Consumer Data Protection Act of 2021 ("VCDPA") or Utah residents within the scope of the Utah Consumer Privacy Act ("UCPA").
Unless otherwise defined in this VA/UT Notice, all terms defined in this Privacy Policy and all other terms defined in the VCDPA or UCPA have the same meaning when used in this VA/UT Notice.
This VA/UT Notice supplements the information contained elsewhere in this Privacy Policy and applies to personal data of residents of the Commonwealth of Virginia or the State of Utah ("consumers" or "you"), created, received, transmitted or maintained by or on behalf of GOLO.
Personal Data
In this VA/UT Notice, "personal data" means information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include: a) deidentified data that is maintained in a form that cannot reasonably be used to link to an identified or identifiable person, or a device linked to such person; b) publicly available information from federal, state or local government records or information that we have a reasonable basis to believe was lawfully made available to the general public through widely distributed media without restrictions; c) information about job applicants, employees and other personnel; or d) information about the employees and other representatives of third-party entities who we may interact with in a commercial context. For Utah residents, aggregated data that relates to a group or category of consumers is also not personal data.
We process the categories of personal data further described in the "Personal Information We Collect and How We Collect It" section of this Privacy Policy and as shown in the table below.
Personal Data Recipients
As described further in the "How We Disclose Your Personal Information" section of this Privacy Policy, we share personal data with service providers or processors that help us operate our Platform and Services and provide our Products. We may also share personal data with a variety of third parties, including for marketing purposes; if we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.
For purposes of this VA/UT Notice, when we use the term "third party" we mean entities that are not a GOLO entity or processors providing services on behalf of GOLO and that are not entities with whom you interact with directly.
We have collected the categories of personal data as noted in the table below and disclosed it to the categories of third parties listed below. The table also indicates when we sold the personal data to third parties or processed such information for targeted advertising.
Category of Personal Data |
Categories of Third Parties to Whom Personal Data is Disclosed for Specific Processing Purposes |
Sold or shared with Third Parties for Targeted Advertising |
Categories of Third Parties to Whom Personal Data Is Sold or Shared for Targeted Advertising |
---|---|---|---|
Identifiers, such as name, email address and other information. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising / marketing / media partners; social networks |
Protected Classification Characteristics such as ethnicity and gender. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Commercial Information, such as shopping history and other information relating to your hobbies, interests and shopping behavior. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising / marketing / media partners; social networks; data analytics platforms |
Biometric Data, such as behavioral characteristics used to identify you; fingerprint, voiceprint, eye retinas, irises, or other unique biological patterns or characteristics that are used to identify you. |
N/A |
N/A |
N/A |
Internet/Network Information, such as browsing history, search history, and information regarding your interaction with an internet website application or advertisement, such IP address, device information, and log and analytics data. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising / marketing / media partners; social networks; data analytics providers |
Geolocation Data, such as location information from your device or estimated based on your IP address. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising / marketing / media partners; social networks; data analytics providers |
Sensory Information, such as recordings of phone calls between you and us, where permitted by law. |
Service providers, including those that assist with order fulfillment, customer service, and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
Other Personal Data, such as information you post on our Platform or on social media pages, and information you submit to us. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Product review services |
Profile Data, such as information generated by processing personal data to evaluate, analyze or predict your interests, economic situation, behavior, location, movements or preferences. |
Service providers, including those that assist with order fulfillment, supply chain, loyalty programs, and similar support services; law enforcement and government authorities or agencies if required |
X |
Advertising / marketing / media partners; social networks; data analytics providers |
Sensitive Data, such as data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, genetic or biometric data for the purpose of identifying you individually, personal data from a known child (under age 13), or precise geolocation data. |
Service providers, including those that assist with order fulfillment and similar support services; law enforcement and government authorities or agencies if required |
N/A |
N/A |
We sell personal data and process it for targeted advertising purposes, which means we display advertisements to you based on information we obtain about you through nonaffiliated websites, online applications, or online services to predict your interests or preferences. We sell or share your personal data for the purposes further described in the "How We Disclose Your Personal Information" section of this Privacy Policy. Please see your rights to opt out from these activities listed in the "How to Exercise Your Privacy Rights" section below.
Purpose for Processing
We process personal data for different purposes, depending on how you interact with the Platform, Products, and Services. We process personal data about you for the purposes described in the "How We Use Your Information" section of this Privacy Policy.
Your Virginia or Utah Privacy Rights
As a Virginia or Utah resident, you may be able to exercise the following rights in relation to the personal data that GOLO or our processors have collected (subject to certain limitations at law):
Right to Know |
The right to confirm whether or not we are processing your personal data. |
---|---|
Right to Access / Data Portability |
The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible. |
Right to Request Deletion |
The right to request the deletion of personal data we have collected from or about you, subject to certain exceptions. |
Right to Opt Out |
The right to direct us not to process your personal data for certain types of targeted advertising, to sell your personal data, or to process your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects on you. |
Right to Correct |
Virginia residents have the right to request us to correct inaccuracies in the personal data we maintain about you. |
Right to Appeal |
Virginia residents may also have the right to submit an appeal if your request is denied. |
How to Exercise Your Rights
We will need to verify your identity and confirm you are a resident of Virginia or Utah before processing most requests, which may require us to request additional personal data from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of information you provide us to the information we maintain about you in our systems. We will use the personal data provided in connection with a request as needed to review and comply with the request. If you do not provide the necessary information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of a Virginia or Utah resident (including a minor child), we will also need sufficient information to verify that the individual is the person about whom we collected personal data and that you are authorized to submit the request on their behalf.
In certain circumstances, we may decline a request to exercise the rights described above. If you are a Virginia resident and your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at privacy@golo.com.
To Exercise Your Rights to Know, Access / Data Portability, Correct, or Delete
Please submit a request by filling out our Privacy Rights Request form or by calling 1-800-503-2390.
To Exercise Your Right to Opt Out of Targeted Advertising, Sales, or Profiling
To exercise your right to opt-out of targeted advertising, personal information sales or profiling, please submit a request by clicking here or by clicking the "Your Privacy Choices" link on our Platform then select the "Do Not Sell or Share My Personal Information" button.
Once you make an opt-out request, you may change your mind and opt back in to personal data sales at any time by contacting us at privacy@golo.com.
Sensitive Data and Personal Data of Children Under Age 13
When required by applicable law, we will only process your sensitive data if we obtain your consent. We do not process personal data of consumers we know to be less than 13 years of age and will not do so unless we receive affirmative authorization from the parent or guardian.