Privacy Policy

This privacy policy (“Privacy Policy”) sets out the types of information Sixpenny, Inc. (“Sixpenny”, “we”, “us”, or “our”) collects, uses and shares about you when you visit or use the Sixpenny website (hereinafter, “the Website” or “Website”) , and all related services, features, and content offered by Sixpenny or when you otherwise contact or interact with us (collectively, “Services”). The terms “you” and “your” refers to you, the user. This Privacy Policy also explains how Sixpenny may use and share your Personally Identifiable Information (as defined in the Section titled “Information Collected”), as well as the choices available to you. 

By using/continuing to use the Services, you acknowledge you have read and understand and agree to the collection, storage, use, and disclosure of your Personally Identifiable Information as described in this Privacy Policy, and you agree to the Terms of Service which is incorporated by reference. If you do not agree, please do not access or use the Services.

Sixpenny may change this Privacy Policy periodically by posting updates to this Website. You should check this page from time to time to ensure that you continue to agree with the terms of this Privacy Policy. Your continued use of or access to the Services following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.

This Privacy Policy applies to all information collected or submitted on or through the Services. While using the Services, you may have the opportunity to register for services, order products, make requests, and post content, and accordingly, depending on the process, you may be asked to provide or we may collect certain information and content about you. When we talk about “Personally Identifiable Information” in this Privacy Policy, we are generally talking about any information described in this section:

• Name;
• Postal Address;
• Email address;
• Phone number;
• Age;
• Gender or other demographic, statistical or aggregate information about you (but individually does not identify you);
• GPS location information;
• Credit card or payment information. Note: We do not collect or store payment card information ourselves; rather we rely on third party payment processors (e.g., Stripe) to store and process this information as part of the Services;
• Information about your computer and internet connection, including your device or computer operating system, IP address, browser type, and browser language. Note: IP addresses are not linked to Personally Identifiable Information; and
• Other transaction information, including, for example, the details of purchases and other transactions or payments made with us or with some of our business partners affiliated with our Services.

Please note that the various privacy laws throughout the United States and around the world defined Personally Identifiable Information differently. While the list above is intended to be complete, it is possible that other types of data we collect, process or share may also be considered Personally Identifiable Information for purposes of this Privacy Policy.

Sixpenny takes your privacy very seriously. Accordingly, we agree that we will only use the information you provide for the following specific purposes: to effectuate a registration made by you; to customize the advertising and content you see; to respond to comments, questions, and provide customer service; to communicate with you about an account (e.g., retrieve your password); to fulfill your requests for products and services (including purchases); to operate and improve the content and overall look and feel of our Services; to conduct research, and provide anonymous reporting for internal and external clients, when necessary; in response to a validly-issued subpoena, court order, or other legal process; when necessary to establish or exercise our legal rights or defend against legal claims made by you or on your behalf; to analyze trends, track user movement, and gather broad aggregate demographic information for reporting and sponsorship purposes; to fulfill the purpose for which you provide that information, with your consent, or for any other purpose disclosed by us when you provide the information; and/or to contact you about site news, updates and changes to this Privacy Policy.

We may share, disclose or sell aggregated or anonymized information about our users to third parties for a variety of business purposes without any restrictions, including to provide our Services and/or to protect us or others. We may share, disclose or sell information, including your Personally Identifiable Information, in the event of a major business transaction such as a merger, sale, or asset transfer. The following circumstances describe in additional detail the ways we may share, disclose and/or sell your Personally Identifiable Information:  

1. Subsidiaries and Affiliates. We may share your Personally Identifiable Information with our parent companies, subsidiaries, joint ventures, and affiliated companies for purposes of management and analysis, decision-making, and other business purposes, consistent with this Privacy Policy.
2. Service Providers. We may share your Personally Identifiable Information with our third-party service providers, contractors, and any other similar third parties that help us provide our Services. This may include service providers that help us with analytics services or support services, website hosting, email and postal delivery, location mapping, marketing, product and service delivery. Service providers are bound by contractual obligations to keep Personally Identifiable Information confidential and use it only for the purposes for which we disclose it to them.
3. Consent or to Fulfill the Purpose that Information was Provided. We may share your Personally Identifiable Information to fulfill the purpose for which you provide that information, with your consent, or for any other purpose disclosed by us when you provide the information.
4. In the Event of a Merger, Sale or Other Asset Transfer. If we become involved in a merger, acquisition, financing due diligence, divestiture, restructuring, reorganization, bankruptcy, dissolution, sale, or transfer of some or all of our assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), or transition of Services to another provider, your Personally Identifiable Information may be shared with business people, lawyers, accountants, consultants and other parties involved in such process and/or sold or transferred to another business entity or other party as part of the transaction.
5. When Required by Law. We may share your Personally Identifiable Information to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
6. To Enforce Our Rights. We may share your Personally Identifiable Information to enforce or apply this Privacy Policy, our Terms of Service, and other agreements, including for billing and collection purposes.
7. To Protect Lawful Interests. We may share your Personally Identifiable Information if we believe disclosure will help us protect the rights, property, or safety of Sixpenny, our users, partners, agents, and others. This may include exchanging information with other companies and organizations for fraud protection, and spam and malware prevention.

Please note: From time to time, we use non-identifiable aggregate information to better design our Services and to share with select advertising partners, sponsors, and/or affiliates. For example, we might tell an advertiser that X number of individuals visited a certain area on our Website, or that Y number of men and Z number of women filled out our registration form; but in those cases, we do not generally disclose anything that could be used to personally identify particular individuals.

In accordance with applicable law, you may have the right to: 

1. Access Personally Identifiable Information. You may access Personally Identifiable Information about you, including: (i) confirming whether we are processing your Personally Identifiable Information; (ii) obtaining access to or a copy of your Personally Identifiable Information; and (iii) receiving an electronic copy of Personally Identifiable Information that you have provided to us, or asking us to send that information to another company (the “right of data portability”). 
2. Request Correction of Personally Identifiable Information. You may request correction of your Personally Identifiable Information where it is inaccurate, incomplete, or improperly possessed.
3. Request Deletion of Personally Identifiable Information. You may request deletion of your Personally Identifiable Information held by us about you. Please note: we cannot delete your Personally Identifiable Information except by also deleting your account.
4. Opt-out. You may request to opt-out of the processing of your Personally Identifiable Information for the purpose(s) of: (i) targeted advertising; (ii) sale or sharing of personal information; or (iii) profiling to make decisions that have legal or other significant effects on you. 
5. Withdraw Consent. You may have the right to withdraw consent where such consent is required to share, use or sell Personally Identifiable Information.

If you would like to exercise any of these rights, you may send us an email to request access to, correction of or removal of any Personally Identifiable Information that you have provided to us. We will process such requests in accordance with applicable law.

The following are additional Consumer Privacy Rights that might apply, depending on where you are located:

1. Non-Discrimination.  Residents have the right not to receive discriminatory treatment by covered businesses for the exercise of their rights conferred by the applicable privacy law.
2. Authorized Agent.  Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personally Identifiable Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Information” below and provide written authorization signed by you and your designated agent.
3. Verification.  To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personally Identifiable Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services. 

If you are dissatisfied with the refusal of Sixpenny to take action in accordance with the exercise of your rights in the “Accessing and Correcting Your Personally Identifiable Information” section above, you may request reconsideration by Sixpenny, by sending a written request for reconsideration to the mailing address found in the “Contact Information” section below. Within sixty (60) days of Sixpenny’s receipt of such written request for reconsideration, Sixpenny shall inform you in writing (at the address indicated in your initial written request) of any action taken or not taken in response to your request for reconsideration, including a written explanation of the reasons for the decision. In addition, if your request for reconsideration is denied, you may have the right to appeal to the Attorney General in your state of residence.

If you are in the European Economic Area (EEA), you have the right to complain to a Data Protection Authority about our collection and use of your Personally Identifiable Information. For more information, please contact your local data protection authority in the EEA. 

A cookie is a small data file stored on the hard drive of your computer either for (1) the duration of your visit on a website (“session cookies”) or (2) for a fixed period (“persistent cookies”). Sixpenny uses cookies to remember certain user information. This allows users of the Website to avoid logging in more than once, thereby saving time. You may, at any time, disable or refuse to accept cookies by changing the preferences or settings on your web browser. If you choose to disable cookies, you will still be able to use our Website. However, you will not be able to fully take advantage of certain automation and other functionality and features.

Please note: No personally identifiable information is collected with the cookies that we set. Accepting cookies while on the Website will not put the user at risk for marketing to other sites.

The Services may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

You may “opt in” to receive newsletters, promotional offers and other useful information from us. To unsubscribe from our mailings (except important system and content update information detailed below), you may go to the ‘My Account’ section of the Website and edit your personal profile by selecting the “edit my profile” link.

Please note: You may not unsubscribe from receiving service announcements and important content update information regarding the Services, including but not limited to: service and account changes, Website upgrades, and site cancellation or business termination information.

“Do Not Track” (“DNT”) is a privacy preference you can set in certain web browsers. When you turn on this preference, it sends a signal or message to the websites you visit indicating that you do not wish to be tracked. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

We have implemented safeguards designed to secure your Personally Identifiable Information. Such safeguards include the implementation of various technical, physical, administrative and organizational mechanisms, policies and procedures intended to reduce the risk of unauthorized access, disclosure, or modification of your information. All information you provide to us is stored on our servers behind firewalls.

Please note, however, that while we have employed security technologies and procedures to assist safeguarding your Personally Identifiable Information, no system or network can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of Personally Identifiable Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

We keep your information for the length of time needed to carry out the purpose outlined in this Privacy Policy and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect our audit requirements and laws that apply to our business. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, and to comply with our legal obligations. Where we retain data, we do so in accordance with our record retention policies and any limitation periods and records retention obligations that are imposed on us by applicable law.

If you provide Personally Identifiable Information through the Website, you acknowledge and agree that such Personally Identifiable Information may be transferred from your current location to the offices and servers of Sixpenny and the other third parties referenced in this Privacy Policy located in the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of such laws, where applicable.  

Protecting the privacy of children is especially important to us. For that reason, we never collect or maintain information from those we actually know are under 18, nor do we allow registration of users under the age of 18. If we learn that we have inadvertently collected or received Personally Identifiable Information from an individual under the age of 18, we will use reasonable efforts to immediately remove such information, unless we have a legal obligation to keep it. If you are a parent or legal guardian and think your child under the age of 18 has given us information without your consent, please contact us via the information found in the “Contact Information” section below.

Although this Privacy Policy applies to the entirety of Personally Identifiable Information obtained by you for the purpose of accessing or using the Services, it does not apply to third party entities that are not owned or controlled by us. Our Services may contain links to other third party websites or applications, which may have privacy policies that differ from our own. For example, Sixpenny may use social media sites, such as Facebook or Instagram, which have their own privacy policies and which may collect and share certain data. These third parties may also use cookies or other tracking technologies to collect information about you when you interact with their content on the Services, such as vendors using Web beacons and cookies on for payment verification. The information they collect may be associated with your Personally Identifiable Information or they may collect information about your online activities over time and across different websites. Please be aware that Sixpenny does not endorse, screen or approve, nor claim any responsibility for the privacy practices of these third parties or the content of their application or website. We encourage you to be aware when you leave our site and to take reasonable precautions when sharing your personally identifiable information on third party websites. Providing Personally Identifiable Information to third-party websites or applications is at your own risk. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@sixpenny.com.

The California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (CPRA) (together, “CCPA”) requires covered businesses to provide California residents with some additional information regarding how they collect, use, and share your “personal information” (as defined in the CCPA). As such, we have provided additional details below about the information we collect, how we disclose it, and how you can exercise your privacy rights under the CCPA, in the event it applies to our activities in the future.

1. Categories of Personal Information that is Collected, Disclosed and Shared. The CCPA provides California residents with the right to know what categories of personal information covered businesses have collected about them and whether such businesses have disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

   Category of Personal Information Collected	Category of Third Parties Personal Information is Disclosed to for a Business Purpose
   Identifiers A real name, postal address, Internet Protocol address, email address, or other similar identifiers.	Advertising partners Service providers
   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.	Service providers
   Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising partners Service providers
   Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising partners Service providers
   Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising partners Service providers
   Professional or employment-related information Collect the employment information of Customers, to provide the appropriate level of service.	Advertising partners Service providers
   Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address.	Advertising partners Service providers
   Category of Sensitive Personal Information Collected	Category of Third Parties Sensitive Personal Information is Disclosed to for a Business Purpose
   Precise Geolocation Data Any data that is derived from a device, and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by regulations.	Advertising partners

   
   We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the personal information was collected. The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personally Identifiable Information Collected” and “Use of Personally Identifiable Information” above, respectively.
   We may share any of the information listed above with service providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service providers are restricted from using personal information for any purpose that is not related to our engagement.
2. “Sales or Sharing” of Personal Information under the CCPA. California residents have the right to opt out of the “sale or sharing” of their personal information to third parties. The CCPA defines “sale” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for monetary or other valuable consideration (which may be considered “sales” under the CCPA even if no money is exchanged). The CCPA defines “sharing” to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer’s personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

   Category of Personal Information Sold or Shared by Sixpenny	Category of Third Parties Personal Information is Sold or Shared to
   Identifiers A real name, postal address, Internet Protocol address, email address, or other similar identifiers.	Advertising partners Service providers
   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number.	Advertising partners Service providers
   Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising partners Service providers
   Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising partners Service providers
   Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising partners Service providers
   Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address.	Advertising partners Service providers

3. Opt-out of “Sales or Sharing”.  California residents may opt-out of the “sale or sharing” of their personal information by contacting us as set forth in “Contact Information” above. California residents (or their authorized agent) may also exercise their right to limit the disclosure of their sensitive personal information, by clicking on this “Opt-Out Rights” link. 

The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to exercise any of your rights under the law, please contact us as set forth in “Contact Information” above. We will process such requests in accordance with applicable laws.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personally Identifiable Information to third parties who intend to sell or license that Personally Identifiable Information, even if your Personally Identifiable Information is not currently being sold. If you would like to exercise this right, please contact us via the information found in the “Contact Information” section above.

Residents of Virginia, Colorado, Connecticut, Oregon, Texas and Utah may have additional rights under relevant privacy laws, including under the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), and Oregon Consumer Privacy Act (“OCPA”), Texas Data Privacy and Security Act (“TDPSA”) and Utah Consumer Privacy Act (“UCPA”), as applicable. The following additional information is required to be provided by covered businesses under applicable state laws.

1. Sharing/Disclosing of Personal Data.The VCDPA, CPA, CTPDA, OCPA, TDPSA and UCPA require covered businesses to provide residents of their respective states with the right to know the categories of “personal data” (as defined under applicable law) covered businesses shared with/disclosed to third parties and the categories of third parties with whom such personal data has been shared/disclosed. Residents of Virginia, Colorado, Connecticut, Oregon, Texas and Utah can find this information below: 

   Category of Personal Data Shared	Category of Third Parties Personal Data is Shared With/Disclosed to
   Identifiers A real name, Internet Protocol address, email address, or other similar identifiers.	Advertising partners Service providers
   Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising partners Service providers
   Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising partners Service providers
   Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising partners Service providers
   Professional or employment-related information Collect the employment information of Customers, to provide the appropriate level of service.	Advertising partners Service providers
   Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address.	Advertising partners Service providers

2. “Sales” or Processing for Targeted Advertising. Residents of Virginia, Colorado, Connecticut, Oregon, Texas and Utah have the right to opt-out of the “sale” of their personal data to third parties or the processing of their personal data for targeted advertising (see “Accessing and Correcting Your Personally Identifiable Information” above). For purposes of this paragraph the definition of “targeted advertising”, “sale”, “sell” or “sold” has the meaning set forth in the applicable state privacy law. However, please note, in accordance with applicable privacy law certain specific exceptions to “sale” and/or “targeted advertising” may apply, including the disclosure of personal data to a processor that processes personal data on behalf of a controller. If a consumer wishes to exercise their right to opt-out of the sale of personal data or processing of personal data for targeted advertising, they may do so by following this link. Sixpenny only currently processes personal data for purposes of targeted advertising. The categories of personal data “sold” or processed for targeted advertising can be found below:

   Category of Personal Data Sold to Third Parties or Processed for Targeted Advertising	Category of Third Parties Personal Data is Sold to or Processed by for Targeted Advertising
   Identifiers A real name, Internet Protocol address, email address, or other similar identifiers.	Advertising partners Service providers
   Personal information categories A name, address, telephone number.	Advertising partners Service providers
   Commercial information Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising partners Service providers
   Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising partners Service providers
   Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising partners Service providers
   Geolocation data As described above, we may collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device’s IP address.	Advertising partners Service providers

3. State-Specific Rights to Opt-Out. 
   • A. Colorado, Connecticut, Oregon, Texas and Virginia. Residents of Colorado (or an authorized agent thereof), Connecticut (or an authorized agent thereof), Oregon, Texas and Virginia may request to opt-out of the processing of your personal data for the purpose(s) of: (i) targeted advertising; (ii) sale of personal data; or (iii) profiling to make decisions that have legal or other significant effects on you. If you would like to exercise this right, you may send us an email to request to opt-out. We will process such requests in accordance with applicable law. Please note: You may also broadcast an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal).
   • B. Utah. Utah residents may request to opt-out of the processing of your personal data for the purpose(s) of: (i) targeted advertising; or (ii) sale of personal data. If you would like to exercise this right, you may send us an email to request to opt-out. We will process such requests in accordance with applicable law.
4. Connecticut Right to Appeal a Denied Appeal. If you are a resident of the State of Connecticut and your request for reconsideration of Notable’s refusal to take action in accordance with the exercise of your rights in the “Accessing and Correcting Your Personally Identifiable Information” section of the Privacy Policy is denied, you have the right to file a complaint with the Connecticut Office of the Attorney General by visiting the “File a Compliant” page here or contacting the Consumer Assistance Unit at 860-808-5420.