Last updated: Apr 19, 2025

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Hawaii Notice at Collection / State Law Privacy Rights:

See the State law privacy rights section below for important information about your rights under applicable state privacy laws.

 

This Privacy Policy describes how Anthro International LLC and affiliates ("Anthro International," "we", “us” or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, online storefront, and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”)).

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Personal information we collect

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Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, company name, and phone number.

• Demographic data, such as your city, state, country of residence, postal code, and age.

• Profile data, such as the username and password that you may set to establish an online account on the Service, redemption code, biographical details, avatar or picture, videos you have watched and articles read or added to your “My list,” links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.

• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.

• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Payment data needed to complete transactions, including payment card information or bank account number.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

• Partners, such marketing partners and event co-sponsors.

• Service providers that provide services on our behalf or help us operate the Service or our business.

• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Precise geolocation data when you authorize the Service to access your device’s location.

• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, such as the ability to send a gift subscription to another person, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

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Tracking & other technologies

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Cookies and other technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.

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How we use your personal information

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We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service;

• enable security features of the Service;

• establish and maintain your user profile on the Service;

• facilitate your invitations to friends or contacts who you want to invite to join the Service;

• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

• communicate with you about events or contests in which you participate; and

• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;

• personalize your experience with the Service and our Service-related communications; and

• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

• Interest-based advertising. We, our service providers, and third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that we or they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

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Retention

 

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

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How we share your personal information

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We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

Affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Wix or Paypal. Wix and Paypal may use your payment data in accordance with their privacy policies, available at https://www.wix.com/about/privacy and https://www.paypal.com/us/legalhub/paypal/privacy-full, respectively.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events, tours, or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Anthro International, financing of Anthro International, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Anthro International as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

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Your choices

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In this section, we describe the rights and choices available to all users. Users who are residents of Hawaii and certain other states can find additional information about their rights below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.

• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.

• Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:

o Google: https://adssettings.google.com/

o Facebook: https://www.facebook.com/about/ads

• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:

o Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp

o Digital Advertising Alliance: optout.aboutads.info.

o AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

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Other sites and services

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The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

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Security

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We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

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International data transfer

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We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

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Children

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The Service is not intended for use by anyone under 14 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

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Changes to this Privacy Policy

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We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

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State privacy rights notice

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SECTION 1. This Act shall be known as the Hawaii Information Privacy Act.

SECTION 2. The multi-billion dollar commercial trade in personal information -- financial, job-related, medical, and lifestyle -- is one of the fastest growing industries in the world. Such information is treated, in the private sector, as a commodity for development, purchase, and sale. Personal information thus fuels an industry devoted to the thorough tracking, monitoring, and recording of specific aspects of individuals' lives and their interaction with society. In the United States, the person behind each piece of information is largely neglected, and has few if any rights to review that information for accuracy or to restrict the use of that information. Other countries, such as those in the European Union, restrict and control the collection and dissemination of sensitive personal information out of respect for a person's personal privacy interests. In such countries, personal information may be collected, but its usage must be for the purpose for which it was collected, and the individual has certain rights to restrict further distribution as well as the right to review the information for accuracy and to correct it as necessary. The United States in general has not developed comparable individual privacy protections. Hawaii, however, has a unique constitutional right to privacy. Article I, section 7 of our constitution, states that the "right of the people to privacy is recognized and shall not be infringed without the showing of a compelling state interest. The legislature shall take affirmative steps to implement this right." (Emphasis added) The standing committee report of the 1978 Constitutional Convention specified three ways in which the constitutional privacy right applies: to protect an individual from disclosure of the individual's private affairs; to allow an individual of control the privacy of information about the individual; and the right to be left alone in certain highly personal areas of the person's life. The fact that this right applies to private as well as governmental intrusion was highlighted in the committee of the whole report, which stated that "[p]rivacy as used in this sense concerns the possible abuse ... of highly personal and intimate information in the hands of government or private parties[.]" Accordingly, the legislature is specifically authorized, if not required, to propose legislation to protect against privacy encroachment by private entities. While certain personal information needs to be collected in order to accommodate and further current practices in a modern age, safeguards need to be in place to ensure that the privacy intrusions are both consented to and minimized to achieve only the intended purpose. While chapter 92F, Hawaii Revised Statutes, contains constraints on governmental collection and dissemination of information, as well as giving individuals the right to review and correct their own records, corresponding constraints on private business entities are virtually nonexistent. Individual states, as well as the federal government, have been trying to resolve the increasing conflict between the result of easy computer access to data and the right of privacy. This is of increasing concern because of the European Union's recent directive on the protection of personal information. This directive prohibits the transfer of personally identifiable data to other countries that do not provide an adequate level of privacy protection. Failure to comply with these guidelines, or to guarantee equivalent protections, can be cause to restrict trade involving data, a situation that the federal government is endeavoring to avoid in ongoing negotiations with the European Union nations. Hawai`i, with its strong constitutional mandate of individual privacy, must take affirmative steps to ensure privacy even in the absence of federal action. The purpose of this Act, therefore, is to assure the effectuation of an individual's constitutional right to privacy, while providing for the reasonable exchange of information with adequate safeguards to protect its appropriate use.

SECTION 3. The Hawaii Revised Statutes is amended by adding a new chapter to be appropriately designated and to read as 10 follows:

"CHAPTER 12 PRIVACY OF PERSONAL INFORMATION

-1 Purpose. The purpose of this chapter is to  implement the state constitutional right to privacy by providing  safeguards to the collection and dissemination of personal  information about individuals by the private sector. To  effectuate this purpose, this chapter shall be construed liberally to protect each individual's personal information. This chapter: (1) Establishes certain principles with respect to the collection, usage, and dissemination by private sector enterprises of personal data; (2) Assures individuals the right of advance consent to the collection and dissemination of personal information; (3) Provides for accurate, relevant, timely, and complete data collection by private sector enterprises; (4) Enhances private sector accountability by allowing individuals access to their information; and (5) Makes private sector enterprises accountable to individuals for improper collection, usage, or dissemination of personal data.

-2 Definitions. As used in this chapter: "Personal data" means information about an individual which: (1) Identifies or easily leads to the identification of the individual; and (2) Contains data about which the individual has a reasonable expectation of privacy, including financial records, employment records, and purchasing decisions. For the purposes of this chapter, "personal data" does not include medical or mental health data. "Private enterprise" means any private agency, business, organization, or individual who collects or disseminates information on a primarily commercial or for-profit basis. "Private enterprise" does not include the collection, usage, or dissemination for: (1) Journalism; or  (2) Artistic or literary use.

-3 Collection of personal data; limitations. Unless otherwise provided by law or by section -10, personal data shall be collected: (1) Only for a lawful, necessary purpose connected with the function or purpose of the collecting private enterprise; and (2) From the individual and not a third party unless: (A) The individual freely and voluntarily consents to collection by a third party; (B) State or federal law requires the data to be collected; 13 (C) Collection by a third party is necessary to ensure the accuracy of the information; or (D) The information is collected in the interests of the individual and due to exigent circumstances the information cannot be collected in a normal manner. Information collected by a third person shall indicate the source of the information.

-4 Notice to individuals. A private enterprise that collects personal data shall inform the person of the: (1) Purpose of the collection; (2) Use for which the data will be used; (3) Categories of persons in the enterprise who will have access to the data; (4) The place where the data will be kept; and (5) The individual's right of access and ability to correct 6 the information.

-5 Security safeguards; confidentiality. Every private enterprise that collects, uses, or disseminates personal data about individuals shall establish reasonable safeguards to ensure the confidentiality of personal data and to protect the data from loss, misuse, theft, unauthorized access or disclosure, defacement, alteration, or destruction. If an industry develops a de facto standard for privacy safeguards, failure of an enterprise within that industry to meet or surpass that level of safeguards is rebuttable evidence that the enterprise's safeguards are not reasonable.

-6 Limitations on use and disclosure.(a) No personal data shall be used in a manner inconsistent with the purpose as stated to the individual under section -4, or with the consent given by the individual. (b) Unless otherwise authorized by law or consented to by the individual, no private enterprise shall communicate to a third party the personal data collected about the individual. If the individual consents to release to a third party, that third party shall provide at least the same level of privacy protection as the organization that originally gathered the information, and the holder of the information shall not release the information without a guarantee to the third party of this level of privacy protection.

-7 Consent. As used in this chapter, consent to disclosure of personal data by an individual means a knowing, informed, and voluntary waiver, which may be given for general purposes or a specific purpose. Consent shall be valid only for the length of time necessary to achieve the purpose for which it was requested.

-8 Subsequent transmission of personal data. In any subsequent transmission of personal data, whether to an agent, subcontractor, or unrelated third party, the private enterprise shall take all reasonable precautions to ensure that the transferee, whether within the State or not, provides the same or greater levels of protection of personal data as required by this chapter.

-9 Discrimination prohibited. No enterprise shall 21 refuse to respond to a request for goods or services, or to a request relating to employment, on the ground that the individual making the request refuses to disclose personal data, except where: (1) Collection of that data is necessary for the performance of a contract; or (2) Collection of the data is required by law.

-10 Necessary disclosure of personal data. Notwithstanding the requirements of this chapter, a private enterprise shall communicate, without the consent of the 8 individual, personal data on the individual to: (1) The attorney general, if the information is necessary for the purposes of prosecuting an offense under state law; (2) A law enforcement agency that requires it in the performance of its duties; or (3) Comply with a subpoena.

-11 Disposition of personal information. All personal information collected by a private enterprise shall be maintained by the private enterprise for a period of eight years thereafter. Upon the expiration of the eight-year period, the personal information and all copies thereof shall be destroyed.

-12 Criminal penalties. Any person who knowingly or intentionally violates this chapter shall be guilty of a misdemeanor. If the defendant is a corporation or unincorporated association, the court may sentence that private enterprise in accordance with section 706-608 in addition to any other penalty imposed by law.

-13 Civil penalties.(a) In addition to any criminal 4 penalties imposed under section -12, any private enterprise that intentionally or knowingly violates this chapter shall be: (1) Fined not less than $1,000 nor more than $5,000 for each violation; and (2) Subject to the revocation of the right of the private enterprise to collect or disseminate personal data, at the discretion of the court. (b) The court, in issuing any final order in any action brought pursuant to this section, may award costs of litigation, including reasonable attorney's and expert witness fees, to any prevailing or substantially prevailing party whenever the court determines such an award to be appropriate.

-14 Private right of action. Nothing in this chapter shall be construed to prohibit a person aggrieved by a violation of this chapter from commencing a civil action for injunctive relief, actual and punitive damages, or any other remedy provided by law. A violation of this chapter shall be deemed a cause of action for the purpose of the court action."

SECTION 4. This Act shall take effect upon its approval.

 

Additional information for Hawaii residents.

• Sensitive personal information. We do not use or disclose sensitive personal information for purposes that Hawaii residents have a right to limit under the Hawaii Consumer Data Protection Act.

• Retention. The criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.

• Deidentification. We do not attempt to reidentify deidentified information derived from Personal Information, except for the purpose of testing whether our deidentification processes comply with applicable law.

 

• Personal information that we collect, use and disclose. We have summarized the Personal Information (“PI”) we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Privacy Policy above and the categories of Personal Information specified in the HCDPA (Hawaii State Senate Bill §3018). The below summary describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

 

Contact data

• HCDPA statutory categories: Identifiers, Commercial information, Hawaii customer records

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Payment processors, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Demographic data

• HCDPA statutory categories: Identifiers, Hawaii customer records

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Profile data

• HCDPA statutory categories: Identifiers, Commercial information, Hawaii customer records

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Communications data

• HCDPA statutory categories: Identifiers, Commercial information, Hawaii consumer records, Internet or Network Information

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: None

 

Transactional data

• HCDPA statutory categories: Commercial information, Hawaii consumer records, Financial information

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Payment processors, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Marketing data

• HCDPA statutory categories: Identifiers, Commercial information, Hawaii customer records, Internet or Network Information

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Payment processors, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Payment data

• HCDPA statutory categories: Commercial information, Financial information, Hawaii consumer records

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Payment processors, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: None

 

Data about others

• HCDPA statutory categories: Identifiers, Hawaii consumer records

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Payment processors, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: None

 

Device data

• HCDPA statutory categories: Identifiers, Internet or Network Information

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Payment processors, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Online activity data

• HCDPA statutory categories: Identifiers, Commercial information, Internet or Network Information

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Precise geolocation data

• HCDPA statutory categories: Geolocation data

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Advertising partners, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Communication interaction data

• HCDPA statutory categories: Identifiers, Commercial information, Hawaii consumer records, Internet or Network Information

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Third parties designated by you, Professional advisors, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Data derived from the above

• HCDPA statutory categories: Inferences

• Categories of third parties to whom we disclose PI for a business purpose: Affiliates, Service providers, Authorities and others, Business transferees, Partners

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: Advertising partners (to facilitate online advertising)

 

Other Sensitive Personal Information (We do not intentionally collect this information, but it may be revealed in Profile data or other information we collect)

• HCDPA statutory categories: Protected Classification Characteristics

• Categories of third parties to whom we disclose PI for a business purpose: N/A

• Categories of third parties to whom we “sell” or “share” PI for interest-based advertising: None

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