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Privacy Policy

Effective Date: October 1, 2023

GENERAL INFORMATION
1. Welcome to the Privacy Policy of Sandee, LLC. ("Sandee," "we," "us," or "our"). Sandee provides a digital platform that helps people explore the outdoors with a collection of detailed beach information, beach reviews, and photos crowdsourced from a community of beachgoers, beach lovers, and travelers worldwide. This Privacy Policy applies to the following services operated by Sandee (collectively, the "Service"):
  1. www.Sandee.com and other websites owned and/or operated by Sandee that contain a link to this Privacy Policy (collectively, the "Site");
  2. All services made available by Sandee through our website (the "Service".)
2. This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices.
3. This Privacy Policy constitutes an integral part of our Terms of Service, accessible at: www.sandee.com/terms.
4. Please read this Privacy Policy before using our Service or submitting any Personal Data to Sandee and contact us if you have any questions.
INFORMATION WE COLLECT
1. When you contact us or interact with our Service, we collect information that alone or in combination with other information could be used to identify you ("Personal Data") as follows:
  1. Personal Data You Provide to Us: We collect Personal Data when you sign up for our Service through our awesome website. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it may include any of the following:
    1. Account Data: When you sign up, some information is required to create an account on our Service, such as your name, username, email address, and mailing address.
    2. Social Media Data: We have pages ("Social Media Pages") on social media sites like Facebook, Instagram, Pinterest, Twitter, and LinkedIn (each a "Social Media Site"). The platforms that host our Social Media Pages or Social Media Features may provide us with aggregate information and analytics regarding the use of our Social Media Pages and Social Media Features.
    3. User Generated Content: User-generated content, such as profile pictures, photos, images, videos, posts, comments, questions, messages, user interactions, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
    4. Contacts Book Data: Our mobile applications may allow you to synchronize the numbers in your Contacts address book on a regular basis in order to identify any friends and/or relatives who use the Service. When you do so, we will ensure that the relevant data is encrypted and will not use it for any purpose other than matching your contacts to users of the Service. If any of your contacts are using the Service, we will let you know so that you can connect with them. You can revoke our access to your Contacts address book at any time through your mobile device settings.
    5. Additional Information: To help improve your experience or enable certain features of the Service, you may choose to provide us with additional information, such as your date of birth/age, height, weight, gender, profile picture, city of residence, community username, statistics on your beach visit history and your reviews and photographs of beaches.
  2. Information We Generate from Your Use of Our Service: When you visit, use, interact and register with the Service, we may automatically generate certain information about your visit, use, interactions or registration. For example, we may monitor the number of people that visit our Site or Sandee Apps, peak hours of visits, which page(s) are visited on our website the domains our visitors come from (e.g., google.com, bing.com, etc.), and which browsers people use to access and visit our website (e.g., Chrome, Microsoft Internet Explorer, etc.), broad geographical information, and website navigation pattern. In particular, the following information is created and automatically logged in our systems:
    1. Log Data: Information that your browser automatically sends whenever you visit the website. Log data includes your IP address (so we understand which country you are connecting from when you visit the website), browser type and settings, the date and time of your request, and how you interacted with the website.
    2. Cookies Data: We use cookies and similar technologies to operate and administer our Website, make it easier for you to use the Website during future visits, and gather usage data on our Website. For more information about the technologies used and information collected on our Website, please refer to our Cookie Policy, which forms part of this Privacy Policy.
    3. Device Data: Includes the model of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
    4. Usage and Activity Data: We collect information about how you use our website, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of, your activities.
    5. Geolocation Data: If you have enabled location services on your mobile device or on your computer via the website, we may collect your precise location information based on city, state, zip code, country, latitude and longitude. Sandee may also derive your approximate location from the IP address of your computer or mobile device. Geolocation data is used for purposes of directing you to nearby beaches and offering other relevant content and services.
  3. Information We Receive From Third Parties. If you elect to authenticate to our Service using your account on another service (such as a Facebook, Google, or Apple account), we may receive from the other service information like your external account name as well as other information you may choose to make available to us based on your external account settings, such as contact lists and profile photos (if any). You can stop sharing the information from the other service with us by removing our access to that other service.
HOW WE USE PERSONAL DATA
1. We use your Personal Data for a variety of purposes, which are listed in the table below. If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy to explain any such new purpose.
  In addition, in respect of each of the purposes for which we use your Personal Data, privacy laws in certain jurisdictions require us to ensure that we have a legal basis for that use. Most commonly, we will rely on one of the following legal bases:
  1. Where we need to process your Personal Data to deliver our Service to you, or to otherwise perform our contractual obligations to you ("Contractual Necessity").
  2. Where we need to process your Personal Data for our legitimate business interests, and your interests and fundamental rights do not override those interests ("Legitimate Interests").
  3. Where we need to process your Personal Data to comply with a legal or regulatory obligation ("Compliance with Law").
  4. Where we have your specific consent to carry out the processing for the purpose in question ("Consent").
2. Marketing
  1. We may contact you to provide information we believe will be of interest to you. For instance, if you elect to provide your email address, we may use that information to send you promotional information about our products and services. If we do, we will only send you such emails if you consent to us doing so at the time you provide us with your Personal Data. You may opt out of receiving emails at any time by following the instructions contained in each promotional email we send you or by contacting us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding our Site and Services and to respond to your requests.

HOW WE SHARE AND DISCLOSE PERSONAL DATA
1. In certain circumstances, we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:
  1. Affiliates: Other companies in our corporate group may help us deliver our Service to you.
  2. Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with service providers, including hosting, cloud services, and other information technology services providers; email communication software providers, and email newsletter providers; database and sales services; customer relationship management, customer engagement, and customer feedback services; payment processors; security services; and analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data while performing their duties to us.
  3. Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
  4. Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to
    1. Comply with legal or regulatory obligations, including to respond to lawful requests from public authorities and to meet national security or law enforcement requirements,
    2. Protect and defend our rights or property,
    3. Prevent fraud,
    4. Act in urgent circumstances to protect the personal safety of users of the Site, or the public, or
    5. Protect against legal liability.
  5. Other Users. Your profile and other User Generated Content (except for private messages) may be visible to other users of the Service (which may include all users of the Service or a limited number of users, depending on your privacy settings). For example, other users of the Service may have access to your information if you chose to make your profile or other personal information available to them through the Service, and may also have access to content that you submit to the Service such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of information.
DATA RETENTION
1. We keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.
2. If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
3. To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
UPDATE YOUR INFORMATION
1. If you need to change or correct your Personal Data, please contact us at privacy@sandee.com. We will address your request as required by applicable law.
CHILDREN'S PRIVACY
1. Our Service is not directed to children who are under the age of 16. Sandee does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Sandee through the Service, please contact us and we will endeavor to delete that information from our databases.
CALIFORNIA PRIVACY RIGHTS DISCLOSURES
1. Collection, Disclosure, and Use of Personal Data: The categories of Personal Data we have collected in the preceding 12 months are described above in the "Information We Collect" section. In the preceding 12 months, we have disclosed for business purposes each of the categories identified in that section to the categories of third parties identified in the "How We Share and Disclose Personal Data" section. The business and commercial purposes for collecting Personal Data are described in the "How We Use Personal Data" section. We collect Personal Data directly from you and from external accounts you use to log-in to the Service.
2. Privacy Rights: Where provided for by law and subject to any applicable exceptions, California residents may have the following rights under the California Consumer Privacy Act of 2018 ("CCPA"):
  1. To know the categories of Personal Data that Sandee has collected about you, the business purpose for collecting your Personal Data, and the categories of sources from which the Personal Data was collected.
  2. To access the specific pieces of Personal Data that Sandee has collected about you.
  3. To know whether Sandee has disclosed your Personal Data for business purposes, the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data
  4. To have Sandee, under certain circumstances, delete your Personal Data; and
  5. To be free from discrimination related to the exercise of these CCPA rights.
3. Sandee Does Not Sell Your Personal Data.
4. If you would like to exercise any or all of these rights, you may do so by clicking 'Make a Privacy Request' or contacting privacy@sandee.com. Your authorized agent may submit requests in the same manner. Once we receive your request, we will verify your identity by sending an email to the email address you provide to us.
5. If you have questions about your rights or our disclosures under the CCPA, or to request access to an alternative format of this notice, you may reach us at privacy@sandee.com.
6. Online Tracking and Do Not Track Signals: We and our third-party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to "Do Not Track" ("DNT") signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will describe how we do so in this Privacy Policy.
EEA AND UK USERS
1. Scope: This section applies to users located in the European Economic Area ("EEA") or the United Kingdom ("UK").
2. Data Controller: Sandee, LLC. is the data controller for the processing of your Personal Data. You can find our contact information in the 'Contact Us' section below.
3. EEA + UK Representatives. For requests, inquiries or issues related to our processing of your Personal Data and/or this Privacy Policy, users in the EEA or UK, please contact us at privacy@sandee.com.
4. Legal Bases for Processing. This Privacy Policy (the "How We Use Personal Data" section) describes the legal bases we rely on for the processing of your Personal Data. Please contact us if you have any questions about the specific legal basis, we are relying on to process your Personal Data.
5. Your Rights. Pursuant to applicable privacy laws in the EEA and the UK, you have the following rights in relation to your Personal Data, under certain circumstances:
  1. Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details.
  2. Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
  3. Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
  4. Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
  5. Right to data portability: You have the right to obtain a copy of your Personal Data from us to the extent that it is processed by automated means. We will give you a copy of your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  6. Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    1. If we are relying on a Legitimate Interest to process your Personal Data -- unless we demonstrate compelling legitimate grounds for the processing or we need to process your Personal Data in order to establish, exercise, or defend legal claims.
    2. If we are processing your Personal Data for direct marketing -- we may keep minimum information about you in a suppression list in order to ensure your choices are respected in the future and to comply with data protection laws (such processing is necessary for our and your legitimate interest in pursuing the purposes described above).
  7. Right to withdraw consent: If we rely on your Consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your Personal Data before we receive notice that you wish to withdraw consent.
  8. Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to your local data protection authority.
6. Typically, you will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data. This is a security measure to ensure that your Personal Data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information about your request to speed up our response.

We try to respond to all legitimate requests within one month of receipt. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made several requests. In this case, we will notify you and keep you updated.

Please see the 'Contact Us' section below for information on how to exercise your rights.

INTERNATIONAL TRANSFERS
1. Sandee is based in the United States. Some of our vendors and service providers may also be located in the United States or another country. As such, any processing of your Personal Data may involve an export of your Personal Data outside of your country of residence, including to countries which may have data protection laws that are less stringent than the laws in effect in the country in which you are located. Whenever we transfer your Personal Data out of your country of residence, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards that comply with applicable privacy laws. If you would like to receive more information about these safeguards, please contact us.
LINKS TO OTHER WEBSITES
1. Our website may contain advertisements for or links to other websites, products, or services not operated or controlled by Sandee, including Social Media Sites ("Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third-Party Sites directly for information on their privacy practices and policies.