Privacy Policy

 PRIVACY POLICY

Last Updated: 10/19/2022

This privacy policy explains how personal information is collected, used, disclosed and

secured by Smuggler's Cove.

when you (“you”, “your”, “user”) access the Company web site(s) atwww.smugglerscove.net; if more than

one, include all and make “Site” plural (i.e., “Sites”)] If you do not agree to the terms of

this Policy, please do not use the Site(s).

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes

have been made by indicating on the Policy the date it was updated. We encourage you to review this

Policy from time to time to make sure that you understand how any personal information you provide will

be used. Your continued use of the Site(s) following the posting of changes to these terms will mean you

accept those changes. [Note that for material changes, such as how personal information is used and

shared, you will need to consult your attorney regarding whether or not to send out a notice to users and

obtain each user’s affirmative opt-in to the updated Policy.]

What Is Personal Information?

As used herein, the term "personal information" means information that specifically identifies an

individual (such as a name, address, telephone number, mobile number, e-mail address, date of birth,

credit card number, social security number), or information about that individual that is directly linked to

personal information. [Note that if Company collects sensitive personal information (like social security

numbers, bank details and credit card numbers), all pages collecting the sensitive information must use a

secure processing server (https://) and have a clearly visible link to this Policy.] Personal information

does not include “aggregate information”, which is data we may collect about the use of the Site(s) or

about a group or category of users, from which individual identities or other personal information has

been removed. This Policy in no way restricts or limits our collection and use of aggregate information.

PROVIDED AS A COURTESY ONLY

NOT LEGAL ADVICE

How Do We Collect Information, and What Types of Information Do We Collect?

We collect several types of personal information about you in a number of ways when you visit or use the

Site:

Active Collection:

We collect certain information when you voluntarily provide it, such as if you send us an email [and

Insert any means by which users might voluntarily provide information through the Site, e.g., by creating

an account on the Site, subscribing to a newsletter, participating in a community forum or chat room,

shopping on the Site, making a purchase on the Site, receiving customer or technical support,

participating in contests, sweepstakes, events or promotions, etc. If you have purchased ReachLocal’s

TotalLiveChat product, be sure to include “receiving customer or technical support (including via an

online chat widget).”] or you otherwise provide or request information. Such information may include

various types of personal information. Additionally, we may also collect demographic information such

as your age, gender, country and zip code of residence, recent purchases, and preferences. This

demographic information may be associated with your personal information. If this demographic

information is connected with personal information, we will treat the demographic information as

personal information.

Passive Collection:

When you use the Site, some information is also automatically collected, such as [Insert the various types

of information, if any, that may be automatically collected by users of the Site, e.g., Internet Protocol (IP)

address, operating system, browser type, address of a referring web site, activity on the Site, etc.]. We

treat this information as personal information if we combine it with or link it to any of the personal

information mentioned above. Otherwise, it is used in the aggregate only. [Only include the previous two

sentences if they are accurate. Otherwise, disclose how the information will be treated.]

[If the Site uses cookies or web beacons, or if you have registered for ReachLocal’s Latent Conversion

Tracking and/or enabled Remote Conversion Tracking product(s), insert the following paragraph.

Otherwise delete.] We may also automatically collect certain information and monitor user activity

through the use of "cookies" (including persistent and/or session cookies) or web beacons (also known as

web bugs, pixel tags, tracking pixels, or clear gifs) on the Site. A “persistent cookie” is stored on a user’s

hard drive until it expires (persistent cookies are set with expiration dates) or until the user deletes the

cookie. Persistent cookies help websites remember your information and settings when you visit them in

the future. “Session cookies” are cookies that expire upon the conclusion of your visit to a website.

These types of cookies are widely used to facilitate a consumer’s interaction with a website. [Insert a

statement describing whether (or not) the cookies and web beacons collect or link to identifying

information, and if so, how the information is treated (i.e., like personal information above, or

otherwise).] If you wish to block, erase, or be warned of cookies on the Site, please refer to your browser

manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this

could affect certain features on the Site. In addition to the above, information provided by cookies, web

beacons, or other devices may be used, among other things, to [Insert how the information might be used,

e.g., to analyze data, to determine the popularity of content, to deliver targeted advertising, to make

recommendations to users, to better understand the Site’s usage or the effectiveness of Ads, to track user

actions/behavior on the Site, etc. If you have registered for ReachLocal’s Latent Conversion Tracking

and/or enabled Remote Conversion Tracking product(s), be sure to indicate each of the foregoing

purposes, as applicable, such as tracking web events or site visits, and emails to you].

[If you have purchased ReachRetargeting or Reach Display Awareness for implementation on your

website(s), consider incorporating the following and make sure that it’s consistent with the other sections

of your privacy policy:]

We work with a company called ReachLocal, which assists us in advertising our products and/or services.

One of the products that we have purchased from ReachLocal is a retargeting product, which enables

ReachLocal to show you advertisements for our Site when you visit other sites in the ReachLocal network

or in third-party networks. ReachLocal is able to do this through the use of cookies that are provided by

ReachLocal through its third-party partners (the “Advertising Cookies”). The sole use of these cookies is,

as stated above, to simply show you advertisements for our site, they are not being used to track you in

any other way. Moreover, ReachLocal does not link the information in the cookies or any other cookie to

any personal information that you may have provided.

You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies,

though either of those actions may affect the use of our Site. However, if you wish to opt out of any of

the Advertising Cookies, you can do this simply by navigating to http://www.reachlocal.com/opt-out,

which will take you to a web page where you will be able to opt out of the Advertising Cookies currently

used in connection with ReachLocal’s remarketing product.

If you have any questions regarding ReachLocal and/or the Advertising Cookies, you are encouraged to

contact ReachLocal at privacy@reachlocal.com.

[If advertisements are run on the Site(s) via third party ad servers, please consult your attorney to include

disclosures pertaining to such practices. Further, if Company obtains non-personal information about

users (e.g., demographic, geographic, other usage information) from third parties, consult your attorney

to include disclosures pertaining to such practices.]

How Do We Use the Personal Information We Collect?

We use personal information we collect through the Site for the purposes described in this Policy or

elsewhere on the Site. For example, we may use personal and other information we collect to [Insert here

the various ways that Company might use personal information, e.g., to process transactions, request

feedback, communicate with the user, contact the user about their account, respond to user

inquiries/problems, deliver targeted ads, provide recommendations, monitor Site usage trends, send

promotional messages, confirmations, or security alerts, prevent fraud, conduct surveys, etc. If you

purchase ReachLocal’s TotalLiveChat product, include all of the foregoing (other than “deliver targeted

ads”, which is not done via personal information collected via TotalLiveChat). Of course, if you use PII

to deliver targeted ads, you should include that regardless of whether you purchase TotalLiveChat.] and

for any other purpose for which the information was collected.

If you no longer wish to receive [Describe all applicable direct communications, e.g., email, phone calls,

direct mail, etc.] from us, you may opt out of all future communications by [Insert the method by which

users may opt out of future communications.].

PROVIDED AS A COURTESY ONLY

NOT LEGAL ADVICE

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Further, we may make collected personal information available to third parties for their marketing and

promotional purposes.  If you decide that you do not want us to share your personal information with

these companies for their marketing and promotional purposes, please send an e-mail to _____________. 

In this email state that you would like Company to not share your personal information with third parties

for their marketing purposes.  Your opt out request will be processed within thirty (30) days of the date of

which we receive it.  [Remove this paragraph if Company is not going to share personal information for

third party marketing and promotional purposes and doesn’t want to reserve the right to do so. Also,

please note that if this provision is applicable and you’re a California company or have California

consumers, you may have to specifically call out such obligations under a heading entitled “Your

California Privacy Rights,” such as the following:

Your California Privacy Rights: The following applies solely to California residents who have an

established business relationship with Company. If we collect personal information from you, we may

make the personal information available to third parties for their marketing and promotional purposes. If

you decide that you do not want us to share your personal information with these companies for their

marketing and promotional purposes, please send an e-mail to _____________. In this email state that

you would like Company to not share your personal information with third parties for their marketing

purposes. Your opt out request will be processed within thirty (30) days of the date of which we receive

it.].

What Personal Information Do We Share With Third Parties?

We will not share the personal information we collect from you through the Site(s) with third parties,

except as described in this Policy or on the Site(s). For example, we may share personal information as

follows: [List all of types of people/companies with whom the personal information is shared and the

circumstances under which Company would provide such information, e.g., to service providers in

connection with the operation of the Site and/or the marketing of our products and/or services, upon user

request or with user consent, to enforce the Policy, to enter you in sweepstakes, contests or promotions, to

comply with law, to prevent fraud, in connection with the sale of Company assets, etc. If you purchase

TotalLiveChat, be sure to include “to service providers in connection with the operation of the Site

and/or the marketing of our products and/or services.”]

Aggregate Information: [If the Site uses or shares aggregate information, consider including the

following type of language (with adjustments as applicable).]

We may take your personal information and make it non-personally identifiable, either by combining it

with information about other individuals (aggregating your information with information about other

individuals), or by removing characteristics (such as your name) that make the information personally

identifiable to you (i.e., de-personalizing your information). This can include usage information and/or

information that is not connected to personal information. Given the nature of this information, no

restrictions apply under this Privacy Policy on our right to aggregate or de-personalize your personal

information, and we may use and share in any way with third parties the resulting non-personally

identifiable information.

Purchase or Sale of Businesses:

From time to time, we may purchase a business or sell one or more of our businesses and your personal

information may be transferred as a part of the purchase or sale. If we purchase a business, the personal

information received with that business would be treated in accordance with this Policy, if it is practicable

and permissible to do so. If we sell a business, we will include provisions in the selling contract requiring

the purchaser to treat your personal information in the same manner required by this Policy (including any

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NOT LEGAL ADVICE

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amendments to this Privacy Policy). The provisions of this paragraph will also apply if we are sold as part

of bankruptcy proceedings. [Please confirm the foregoing is true and adapt/revise as necessary.]

Disclosures Required By Law and Disclosures to Help Protect the Security and Safety of Our Websites

and Others:

We will disclose personal information when we believe in good faith that such disclosures (a) are required

by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our

policies; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security,

including the safety and security of property that belongs to you; and/or, protect the safety and security of

our Site(s) or third parties.

PROVIDED AS A COURTESY ONLY

NOT LEGAL ADVICE

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How Can You Modify Or Delete Your Personal Information?

You may modify or delete the personal information collected through the Site at any time by [Describe

all methods available to users for them to modify or delete their personal information, e.g., visiting your

profile, modifying your account, contacting Company via email and/or phone, etc.].

Does This Policy Apply to Other Websites Linked To From the Site(s)?

The Site(s) may contain links to other websites. Any personal information you provide on linked pages

or applications is provided directly to that third party and is subject to that third party’s privacy policy.

This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and

security practices and policies of these websites or any other sites that are linked to or from the Site(s).

We encourage you to learn about their privacy and security practices and policies before providing them

with personal information.

Do We Collect Information From Children Under the Age of 13?

The Site(s) is not intended for use by children under the age of 13, and Company does not knowingly

collect or use any personal information from such children. If we become aware that we have

unknowingly collected personal information from a child under the age of 13, we will make commercially

reasonable efforts to delete such information from our database. [Include the foregoing if accurate. If,

however, personal information is collected from children under the age of 13, additional provisions will

be needed, and Company will need to comply with the Children’s Online Privacy Protection Act. Please

consult your attorney for further information.]

What Steps Do We Take To Protect Your Information?

[Consider revising this section as appropriate to reflect your actual practices.] We take measures

designed to protect your personal information in an effort to prevent loss, misuse, and unauthorized

access, disclosure, alteration, and destruction. We provide physical, electronic, and procedural safeguards

to protect information we process and maintain. Please be aware, however, that despite our efforts, no

security measures are perfect or impenetrable and no method of data transmission can be guaranteed

against any interception or other type of misuse. [Consider including the following if relevant.] To

protect the confidentiality of personal information maintained in your account, you must keep your

password confidential and not disclose it to any other person. You are responsible for all uses of the

Site(s) by any person using your password. Please advise us immediately if you believe your password

has been misused.

Miscellaneous

This Policy and the privacy practices of Company will be subject exclusively to the laws of the State of

[Insert chosen state.] in the United States. Company makes no representation that this Policy and our

practices comply with the laws of any other country or jurisdiction. Users of the Site who reside outside

the United States do so on their own initiative and are responsible for compliance with local laws, if and

to the extent local laws are applicable. If you reside outside of the United States, by using the Site, you

consent to the transfer, processing and use of your information outside your country.

Questions?

If you have any questions about this Policy, please contact us at [Insert applicable contact information.]