WEHOGATEWAY.COM PRIVACY POLICY

Last Updated: October 6, 2021

West Hollywood Gateway, on behalf of its subsidiaries and divisions (collectively, “West Hollywood Gateway,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Policy”) to describe to you, or if you represent an entity or other organization that entity or organization (in either case, “you,” or “your”), our practices regarding the personal information that West Hollywood Gateway collects, uses, and shares through the website or application that links to this Policy (each a “Service”). Capitalized terms not defined in this Policy shall have the meanings given to them in the West Hollywood Gateway Terms of Use.

By using this Service you are consenting to the collection, use, and disclosure of your Personal Information as set forth in this Policy. If you do not agree to be bound by this Policy, you may not access or use this Service. By using the Service, you further represent and warrant that you (i) are located inside the U.S., or (ii) are located outside the European Union (“EU”) and agree to be bound by U.S. laws. You may not use the Service from the EU. Use of and access to the Site is void where prohibited.

West Hollywood Gateway reserves the right, at any time, to modify this Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Policy and change the “Last Updated” date above. Your continued use of the Service following posting of changes constitutes your acceptance of such changes.

1. COLLECTION OF PERSONAL INFORMATION
1.1. Personal Information. “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The following are categories of personal information we may collect about you:
CategoriesExamples (without limitation)Processing PurposesA. Individual Identifiers and Demographic InformationEmail, Password, Full Name, Address, Phone Number, Date of Birth, Age Range, Internet Protocol Address, Name and age of child, Demographic Data

To Provide and Improve Our Products and Services
To Set Up Your account on the Service (“Account”)
To Market Products or Services
To Communicate with You

B. ClassificationsGender

To Set Up Your Account
To Improve Our Products and Services

C. Commercial InformationPayment information, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, including information about you obtained from third parties.

To Provide and Improve Our Products and Services
To Understand Your Interests
To Set Up Your Account
To Market Products or Services
To Communicate with You

D. Internet or Network ActivityBrowsing history, search history, information on an individual’s interaction with a website, application, or advertisement. Network and device related information. Social media integration.

To Improve Our Products and Services.
To Market Products or Services
To Secure the Service
To Understand Your Interests

E. Geolocation InformationSpecific location data of individuals who consent to providing such data

To Provide and Improve Our Products and Services
To Understand Your Interests
To Market Products or Services
To Communicate with You

F. Inferences Drawn from Personal InformationProfile reflecting your preferred retailers and interests, purchasing or consuming characteristics.

To Improve Our Products and Services
To Communicate with You

Personal information does not include:

Publicly Available - Publicly available information from federal, state, or local government records.
Deidentified or Aggregate information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which West Hollywood Gateway has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device. We may use Deidentified Information and Aggregate Information for any legal purpose, including without limitation for any purpose for which we use Personal Information.
Excluded Information – Certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. Such laws include the Fair Credit Reporting Act (FRCA); and the Driver’s Privacy Protection Act of 1994. We will notify you separately according to those laws if any of our collection, use, or sharing of personal information falls under any of those laws.

1.2. Sources of Personal Information. We obtain the categories of personal information listed above on or through our Service from the following categories of sources:

Personal Information You Provide. West Hollywood Gateway collects personal information when you voluntarily submit it to us. For example, we may collect or receive personal information from a user that creates an Account; provides information to us in person; signs up to receive promotional communications; participates in one of our promotional sweepstakes, contests, or surveys; posts a review on our Services; submits a request to our customer service team; interacts with our social media pages; or otherwise interacts with us or other users through the Service.
Automatically Collected Personal Information. In addition to personal information that we may receive directly from you, West Hollywood Gateway indirectly collects other information from you automatically through the Service. For example, we receive personal information from users when a user visits and navigates our Service on any device. We may also collect personal information about users over time and across different websites, apps, and devices when a user accesses the Service. We may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. West Hollywood Gateway also collects some personal information automatically using cookies or other online tracking technologies as described in Cookies and Other Technology below.
Personal Information Obtained from Third Parties. In addition to the personal information that we collect from you directly and automatically, West Hollywood Gateway may receive personal information about you from other third-party sources. For example, we receive personal information from our business partners, our network of affiliated malls, or companies that provide personal information to supplement what we already know about users. We may obtain geolocation data from third parties. We may merge or combine such personal information with the personal information we collect from you directly or automatically.

2. USE OF PERSONAL INFORMATION
West Hollywood Gateway’s primary purpose in collecting personal information is to provide the functionality that you request on the Service. West Hollywood Gateway may also use personal information for various purposes, including without limitation to:

To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions. For example, if you share your personal information to participate in a club or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to request a special service like purchasing a gift card or event reservation, we will use such information to assist in your logistics, process your payment, and facilitate delivery of products and services. We may also save your personal information to facilitate new product or service orders.
To Improve Our Products and Services. We use personal information to understand and analyze the usage trends and preferences of our users to make our Services or content better, diagnose technical issues, prevent fraud, deliver promotions and recommendations more efficiently, refine our product and services offerings, and develop new features and functionality.
To Understand Your Interests. We use your personal information to personalize your experience on the Service and with our network of affiliated malls, and to deliver information about products and services relevant to your interests.
To Respond to Your Requests or Questions. We use personal information to provide you with support and to respond to your requests for customer support, including to investigate and address your concerns and monitor and improve our responses. This may also include responding to your feedback.
To Set Up Your Account. If you set up an Account on the Service, including information about you gathered from third party sources, we will use the registration information you provide in relation to that Account (“Registration Information”) creation to create, maintain, customize, and secure your Account.
To Market Products or Services. We use your personal information to provide you with information about our products, services, or promotions. For example, we may use cookies or other online tracking technologies to provide customized advertisements, content, and information; to monitor and analyze the effectiveness of marketing activities; and to track your entries, submissions, and status in any promotions. These might be third party offers we think you might find interesting. These communications may come in the form of interest-based advertising using information gathered across multiple websites, devices, or other services.
To Secure the Service. We use personal information to maintain the safety, security, and integrity of our Service, products and services, databases and other technology assets, business, and other users.
To Communicate with You. We communicate with you about your Account or our relationship. We may also contact you about this Policy or the Terms of Use.
As Required by Law. We use personal information to respond to requests from law enforcement and as required by applicable law, court order, or government investigation.

3. SHARING OF PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this Policy, West Hollywood Gateway may share your personal information in the following circumstances:
3.1. Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.
3.2. Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.
3.3. Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other users; or to prevent a violation of our Terms of Use.
3.4. Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Service. For example, we use Placewise LLC to host our Service; for more information on them, please see their Privacy Policy. Among other things service providers may help us perform website or application hosting, app design, maintenance services, database management, web analytics, app analytics, SMS notifications, payment processing, fraud protection, marketing, or any other use set out in this Policy. Access to your personal information by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function.
3.5. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Service so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Service, or on other websites. Please see Cookies and Other Technology below for more information.
3.6. Affiliated Offerings. We may jointly offer events, promotions, or any other product or service offerings with our network of affiliated malls or merchants. The personal information that you submit through an event, promotion, or other product or service offering offered by any of our network of affiliated malls may be combined and transmitted with the Registration Information related to your Account. Third party partners or clients may collect information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with an affiliated mall or merchant, the information that you provide may be shared with us and with that identified affiliated mall or merchant.
3.7. Social Networking. The Service may offer you the ability to share your personal information through a social networking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
3.8. Aggregate Information. We may also share Aggregate Information and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.
4. SECURITY OF PERSONAL INFORMATION
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
5. COOKIES AND OTHER TECHNOLOGY
“Cookies” are small pieces of information that a website stores on your device while you are viewing a Service. We may use both session cookies (which expire once you close your web browser) and persistent cookies (most of which have an expiration date, based on the purpose of the cookie, at which point they self-delete) to provide you with a more personal and interactive experience on our Services. We place three kinds of cookies: essential, advertising, and performance/analytics.
6.1 Essential Cookies These cookies are strictly necessary to provide you with the Service and to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Service, you cannot refuse them without impacting how our Service functions.
6.2 Non-Essential Cookies We use two kinds of non-essential cookies: performance and advertising. You may opt out of non-essential cookies using the cookie banner on the Service.
Non-essential performance cookies help us analyze how the Service is are being accessed and used, enable us to track performance, and secure the Service. For example, we use those cookies to get insights regarding users and performance, such as page speed or to help us customize our Services for you in order to enhance your experience.
Non-essential advertising cookies are used to make advertising messages more relevant to you and your interests. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited our Service. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after we receive it. This process helps us manage and track the effectiveness of our marketing efforts.
CookieWhat it collectsWhen it’s setPersistent/SessionGoogle Tag Manager
(Essential)It provides measurement codes and related code fragments collectively known as tags on the Service.Page LoadPersistentGoogle Analytics
(Performance)It collects data on a user’s device, browser, location and ad campaign information. It also records behavior on the web, leading up to visiting the site and on the Service.Page LoadPersistent or SessionFacebook Custom Audience
(Advertising)Tracks a user’s ad campaigns and behavior on the web to check for conversions. Also, records agent info such as browser, location, and device.Page LoadPersistentFullStory
(Performance)Analytics data about Service usage.Page LoadSessionWe use generally use cookies and similar technologies as follows:

for “essential” or “functional” purposes, such as to enable various features of the Service like remembering passwords or staying logged in during your session;
for social media integration e.g. via third-party social media cookies, when you share information using a social media sharing button or “like” button, or when you engage with our content on or through a social networking website such as Facebook;
for analytics purposes, consistent with our legitimate interests in how our Service is used or performs, how users engage with and navigate through the Service, what sites users visit before visiting our Service, how often they visit our Service, whether an email was received or opened, and other similar information;
subject to any consent required by law, for the purpose of displaying advertisements via retargeting to those users who have visited our Service, or for targeting advertising to visitors to our Service; and
subject to any consent required by law, for the purpose of analyzing your feedback on our products on other platforms.

If you’d like to remove or disable cookies via your browser, refer to your browser’s configuration.
6. OPTING OUT
You can make the following choices to opt out of certain activities regarding your personal information:
6.1. Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our merchants and featured products, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your Account, to fulfill orders for products and service you have requested, or deliver notifications directly to you through the Service.
6.2. Behavioral Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Service so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Service, or on other websites. If you wish to limit third parties’ collection of information about your use of our Service, you can opt-out of such at the Digital Advertising Alliance or Network Advertising Initiative. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE SERVICE. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
6.3. Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.
7. RIGHTS AND CHOICES FOR CALIFORNIAN USERS
The following applies to individuals in located in California:
7.1. Categories of Personal Information Disclosed for a Business Purpose or Valuable Consideration. West Hollywood Gateway must disclose whether the following categories of personal information are disclosed for a "business purpose" or “valuable consideration” as those term is defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you. In the past twelve months, we have disclosed the following categories of personal information in the manner described.
CategoryInformation is Disclosed for a Business PurposeInformation is Disclosed for Valuable ConsiderationA. Individual Identifiers and Demographic InformationYesNoB. ClassificationsYesNoC. Commercial InformationYesNoD. Internet or Network Activity YesNoE. Geolocation InformationYesNoF. Inferences Drawn from Personal InformationYesNo
7.2. Your Rights. If you are a consumer as defined by the California Consumer Privacy Act (“CCPA”), you have certain rights in relation to your personal information under the CCPA. Under the CCPA, you have the following additional rights:

Access to Your Personal Information and Portability. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account or contacting us as described below. Note that we may keep historical information in our backup files as permitted by law. If our Site does not permit you to update or correct certain personal information, please contact us as described below.
Deletion of Your Personal Information. We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.
Right to Opt Out of Disclosure of Personal Information for Valuable Consideration. We do not sell the personal information of consumers, as those terms are defined under the CCPA. If we do begin to sell Personal Information, we will update this Policy and enable you to submit a request through our webform.
Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Placewise LLC are entitled to ask us for a notice describing what categories of personal information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If You are a California resident and would like a copy of this notice, please submit a written request to us at the addresses listed below.

8. EXERCISING YOUR PRIVACY RIGHTS
When exercising the rights or options described in this Policy, the following guidelines apply:
8.1. No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
8.2. What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.3. Time to Respond. We try to confirm receipt of requests within 10 days and to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
8.4. No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.
8.5. Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
8.6. Accessibility. We have worked to develop our Service to conform to the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines 2.0. These guidelines explain how to make web content more accessible for people with disabilities. For more information, please see Accessibility.
9. CONTACTING US
If you wish to access, update, or correct your personal information, please contact us using the information provided below. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify. Finally, if you have any questions or concerns about our Policy or any other privacy or security issue, please contact us at:
West Hollywood Gateway
Attn: Privacy Agent
7100 Santa Monica Boulevard
West Hollywood, CA 90046
info@wehogateway.com
To request the right to know or delete what data has been collected about you, please fill out our Consumer Data Request Form.
Toll-Free Number: (800) 613-5189