Privacy Policy.
Last Updated: January 24, 2023
This “Privacy Policy” describes how ILLA Inc. and our subsidiaries and affiliates (collectively, “we”, “us”, or “our”) collect, use, and share your personal data in connection with the use of our website, www.weareilla.com, and any other digital properties that we operate that link to this Privacy Policy (collectively, the “Site”), our mobile application (the “App”), and all other services that we offer, whether or not accessed through the Site or App, whether experienced online or in person, whether offered exclusively by ILLA or in partnership with another entity, including, but not limited to, applying for or utilizing a member account, registering for or attending our or a partners’ events, posting or acting in response to content, accessing our newsletter or magazine, and communicating with us through email, online inquiry, members’ chat, or our social media accounts (collectively, the “Services”) (collectively, and together with the Site and the App, the “Platform”), and the rights and choices available to individuals with respect to their personal data.
We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal data, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the date of the latest version of our Privacy Policy at the top of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.
Collection of Personal Data.
Personal Data You Provide to Us. We collect personal data when you voluntarily submit it to us, such as when you apply for membership, subscribe to our newsletter, register for an account, or communicate with us. Personal data you may provide to us through the Platform or otherwise includes:
Chat and message content that you post on the Platform or share with other users of the Platform, including any information or pictures that you include in the chat or message.
Communications that we exchange, including when you contact us with questions, feedback, chats, or otherwise.
Biographical and demographic data, such as your gender, age, date of birth, and location; your activities; and other information that you choose to share in your account profile.
Contact details, such as your first and last name, email address, home address, postal code, and phone number.
Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.
Participation data, such as information you share with us about your ability to participate in certain activities and your participation history in events presented on the Platform.
Payment and transactional data, such as the information needed to complete your orders and registrations on or through the Platform (i.e., name, credit or debit card information, billing information), and information about you membership history.
Profile data and pictures, such as your username and password that you use to establish an online account with us, your social media handle, and any profile picture that you may choose to upload.
Reviews and survey responses, such as your availability to participate in specific events, any reviews and other feedback that you provide on the events offered on our Platform and the answers you provide to our questionnaires and surveys.
Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Sensitive Personal Data. We do not collect, and it is unnecessary for you to provide, sensitive personal data for use on the Platform. We ask that you not share or post sensitive personal data in any chat, message, or other content you post on the Platform.
Personal Data from Third Parties. We may obtain personal data about you from third parties, such as public sources (i.e., social media platforms) and business partners (i.e., joint marketing partners or event co-sponsors).
Referrals. Users of the Platform may have the opportunity to refer colleagues, friends, or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
Personal Data Collected Automatically. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our Platform and other sites and online services, such as:
Device Data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
Online Activity Data, such as login frequency, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Like many online services, we use the following technologies to facilitate some of our automatic data collection:
Cookies, which are text files that websites store on a user‘s device to uniquely identify the user’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Flash Cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
Web Beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
Software Development Kits, or SDKs, which we use in the App. SDKs are third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of our App, to integrate with social media, or to add features or functionality to our App, or to facilitate online advertising. SDKs may enable third parties to collect information directly via our App.
Use of Personal Data.
Our primary purpose in collecting personal data is to provide the services that you request. We may use your personal data for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
To Provide our Products and Services. For example, we may use your personal data to:
verify your identity;
provide you with the content, features, products and services that you request;
establish and maintain your account on the Platform;
process your transactions;
communicate with you about the Platform (including by sending announcements, updates, security alerts, and support and administrative messages);
display your content in the App or on the Site or share your information in a directory;
understand your interests, personalize your experience on the Platform, and deliver information about events and activities relevant to your interests;
assign you to a communications group or channel in our App;
suggest events and activities to you;
respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses; and
fulfill any other purpose for which you provide personal data.
For Research and Development. We use personal data for research and development purposes, including to understand and analyze the usage trends and preferences of our users, to make our Platform and other offerings better, and to develop new features, services, products, and functionality. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal data we collect. We make personal data into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.
For Marketing and Advertising. We, our business partners and our third-party advertising partners may collect and use your personal data for direct marketing and interest-based advertising purposes.
Direct marketing. We may send you direct marketing communications related to our products and services as permitted by law. You may opt-out of our marketing communications as described in the “Your Choices” section below.
Interest-Based Advertising. We also may contract with third-party advertising companies and social media companies to help us advertise our business. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Platform and other sites and services or your interaction with our emails and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” section below.
Compliance and Protection. We may use your personal data to:
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
maintain the safety, security, and integrity of our Platform, products and services, business, databases, and other technology assets;
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 and internal policies;
enforce the terms and conditions that govern the Platform; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With Your Consent. In some cases we may specifically ask you for your consent to collect, use, or share your personal data, such as when required by law or in response to options and opportunities available to you through the Platform.
Sharing of Personal Data
We may share your personal data with the following third parties and as otherwise described in this Privacy Policy or at the time of collection:
Related Companies. Our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.
Service Providers. Companies and individuals that perform services on our behalf or help us operate the Platform or our business. Among other things service providers may help us perform website hosting, maintenance services, database management, web analytics, billing, payment processing, fraud protection, customer service, or marketing.
Business and Integration Partners. Companies and individuals that partner with us to offer certain events, activities, content, promotions and other service offerings or with whom we have agreed to share their events, activities, or other service offerings with our members or through our Platform. For example, we use the Google Places API to provide you with location information relating to events posted to the Platform. When you use Google Maps on the Platform, Google may collect personal data and will use it in accordance with their privacy policy, available here.
Authorities and Others. Law enforcement, government authorities, and private parties as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention, and safety purposes described above.
Business Transferees. If we sell all or part of our business, make a sale or transfer of assets, or are otherwise involved in a corporate divestiture, merger, consolidation, acquisition, reorganization, dissolution, sale, or other disposition of all or any portion of the business or assets of, or equity interests in the business (including any affiliate), whether as an ongoing concern or as part of a bankruptcy, liquidation, or similar proceeding, we may transfer your personal data to third parties as part of that transaction, including at the negotiation stage.
Advertising Partners. Third party advertising companies that collect information about your activity on the Platform and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.
Other Users and the Public. The Platform may provide you with the opportunity to post or make available content, messages, and other information to other users of the Platform or the public. For example, you may be able to participate in a members’ message board or share an event you create through the Platform on a public forum. We do not control how other users or third parties use any personal data that you make available to them. Please be aware that any information you post publicly, including on any members-only message board, can be cached, copied, screen captured or stored elsewhere by others (e.g., other members and search engines) before you have a chance to edit or remove it.
Professional Advisors. We may disclose your personal data to our professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Your Choices.
You can make the following choices with respect to your personal data.
Access or update your personal data. If you have registered for an account with us, you may review and update certain account information by logging into your account.
Opt-out of email marketing communications. You may opt out of marketing-related emails received from us by following the opt-out or unsubscribe instructions at the bottom of the email. After opting-out, note that you may continue to receive service-related and other non-marketing emails.
Opt-out of text messages. We may offer communications via text messages sent by us or any of our service providers, such as when we send you text messages to confirm your identity during account setup, notify you about the status of an event to which you have registered, or for any customer service, account-related, or marketing purpose. To stop receiving text messages from us, reply STOP to any text message you receive from us, or email us your request and mobile telephone. Note that we may send you a message to confirm receipt of your STOP request.
Opt-out of push notifications. Upon download of the App, you may be provided with the option to opt-in to receiving notifications that may include alerts, sounds, and icon badges. Push notifications can be configured in settings on your mobile device.
Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and our Site 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.
We use Google Analytics to help us understand user activity and patterns on the Site. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available here.
Advertising choices Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Some of the third party advertising companies we work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising, such as Google (info and opt-out). Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.
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” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We may need to collect personal data to provide certain services. If you do not provide the information requested, we may not be able to provide those services.
Security.
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal data from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal data.
Other Sites and Services.
The Platform may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal data. We encourage you to read the privacy policies of the other websites and online services you use.
International Transfers of Personal Data.
We are based in the United States of America, and we have service providers in the United States and potentially other countries. Your personal data may be collected, used, stored, and transferred in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal data may not be as protective as the privacy laws in your home country. By providing your personal data, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
Children’s Privacy.
The Platform is not intended for use by anyone under the age of 18, and we do not knowingly collect personal data from children under 18.
Notice to California Residents.
Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with us are entitled to ask us once a year for information regarding the personal data we have shared, if any, with third parties for their direct marketing purposes. If you are a California resident and would like to submit such a request, please submit your request in writing to the address listed in the section titled “CONTACTING US” above and include the words “Shine the Light” in your correspondence. The request must include your name, street address, city, state, and ZIP code and an attestation that you are a California resident. We are not responsible for requests that are not labeled or sent properly, or that do not have complete information.
Notice to Nevada Residents – Your Privacy Rights.
Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal data. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal data for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed below.
Contacting Us.
Please direct any questions or comments about this Privacy Policy or our privacy practices to privacy@illa.co.