PRIVACY POLICY
Introduction
This Privacy Policy (“Privacy Policy”) describes how Hemingway LTD and our parent, subsidiary, and affiliate companies (collectively, “Hemingway LTD,” “we,” “us,” or “our”) collect, use, and protect Personal Information (defined below) that we receive from visitors, users, and customers (“you,” “your”) of our website, https://example.com, and affiliated websites, subdomains, applications, and online media platforms we operate (collectively, the “Service”). Use of the Service is subject to our Terms of Service.
We respect your privacy and are committed to protecting any information that can identify you (“Personal Information”), including any sensitive personal information as defined under applicable data privacy laws (“Sensitive Personal Information”). You may choose what information to share with us. Please note that declining to provide certain information may limit access to some features of the Service. If you do not agree with this Privacy Policy, please do not use the Service.
Our Service may contain links to third-party websites or applications, including social media platforms, which we do not control. These are provided for your convenience only. We are not responsible for their content, privacy practices, or your use of them.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time at our sole discretion. The effective date will be posted at the top of this page. Changes take effect upon posting unless otherwise noted. Continued use of the Service after changes are posted indicates your acceptance. We encourage you to review this Privacy Policy regularly.
Children’s Privacy
Our Service is not intended for children under 16. We do not knowingly collect or sell Personal Information from anyone under 16. If you believe we have received information about a child, please contact us at info@collective222.net. Visit www.OnGuardOnline.gov for tips on protecting children’s privacy.
Information We Collect
We may collect the following categories of Personal Information:
Identifiers: name, username, email, phone number, mailing address, location
Sensitive Personal Information: payment information, account passwords, and information that may reveal characteristics such as race, ethnicity, or religious affiliation
Internet or network activity: browsing behavior, cookies, and preferences
Other information: relevant details needed to deliver or improve our services
We generally do not request government-issued IDs or financial account information unless necessary to fulfill service requests. If required, you may request we limit use of your Sensitive Personal Information under applicable U.S. privacy laws by contacting info@hemingwayltd.com.
Sources of Personal Information
1. Information You Provide Directly
When you register an account, sign up for email or SMS updates, engage with our content or services, or communicate with us directly, you may provide Personal Information, including identifiers and payment details.
We may also collect information from media content (e.g., visual recordings or photos) submitted or shared during interactions with us for internal evaluation or service purposes. This may include inferences related to Sensitive Personal Information. Visual data will not be used externally or shared without your consent.
We also collect information when you send inquiries, feedback, or contact us about services, or when you submit resumes for career opportunities at Hemingway LTD.
4.2 Information Provided by Third Parties
We may collect Personal Information and/or Sensitive Personal Information about you from non-affiliated third parties. For example, when you make a purchase or schedule a service through the Service, our third-party payment processors—currently Visa Authorize.net, WorldPay, and ColdLion (each a “Payment Processor”)—may collect details such as your payment method, billing address, and transaction data. This information may be shared with us through secure, encrypted, and tokenized methods. For more on their data privacy practices, please refer to their respective privacy policies:
Additionally, we may collect your name, email address, mailing address, and telephone number if you submit a resume to us through third-party platforms such as LinkedIn or Indeed for consideration of career or internship opportunities with Hemingway LTD. For more on their data practices, visit their privacy policies:
4.3 Automatically Collected Information
When you access or use the Service, we may automatically collect certain information using software tools for login, security, analytics, and personalization. This data may include:
Log Files: Browser type, Internet Service Provider (ISP), date/time stamps, referring/exit pages, pages clicked, and similar data.
Cookies: Small data files placed on your device. Cookies may be session-based (temporary) or persistent. They help improve user experience and track preferences. Some cookies may be linked to Personal Information.
If you are located in the United Kingdom or the European Economic Area (EEA), we will request your consent to use any cookies that are not essential for the operation of the Service.
Types of Cookies and Your Options:
Required Cookies
Enable core functionality such as secure login and account recognition.
These cookies are necessary to operate the Service.
Cannot be disabled.
Performance Cookies
Collect anonymized data on usage patterns to help us improve performance and functionality.
Can be disabled via browser settings.
Consent required in the UK/EEA.
Functionality Cookies
Store preferences like language or region, enabling a more personalized experience.
Can be disabled via browser settings.
Consent required in the UK/EEA.
Targeting/Advertising Cookies
Used to analyze behavior and provide relevant advertisements.
May track your activity across other sites.
Some partners may re-associate data.
Can be disabled via browser settings.
Consent required in the UK/EEA.
4.4 Other Tracking Technologies
We may also use web beacons—clear electronic images—to collect data about how you use the Service and engage with our communications. For instance, we may embed beacons in emails to track whether you opened the message or clicked on included links. This helps us refine content, monitor effectiveness, and improve overall service delivery.
Purposes For Which We Use Personal Information
If you submit or we collect Personal Information through the Service or as otherwise described above, we may use such Personal Information for the following general purposes:
To provide you with our products and offerings, the Service, and its related features, and to analyze, administer, improve, and personalize the Service;
To communicate with you in connection with the Service and products or offerings made available through the Service, including, without limitation, in connection with relevant status updates for your purchases, and reminders and/or follow-up communications regarding your Appointments;
To send you updates and promotional materials pertaining to Hemingway LTD or the Service;
To provide personalized advertising to you, on the Service and on third-party websites and mobile applications;
To identify and authenticate your access to the parts of the Service that you are authorized to access;
For research and development relating to the Service and the offerings we make available to you through the Service or in person;
For electronic direct marketing in compliance with Applicable Law;
To protect our rights and/or our property and to ensure the technical functionality and security of the Service;
For the performance of our contract with you or to take steps at your request before entering into a contract;
Where you have given consent; and
To comply with applicable law, including, without limitation, under U.S. federal, state, local, and foreign laws, regulations, rules, judicial or governmental orders or requests, legal process, and treaties (as may be amended from time to time, collectively, “Applicable Law”).
How We Disclose Personal Information
6.1 Our Third-Party Providers
We may transfer Personal Information you provide to us through the Service to our third-party service providers and business partners to perform tasks on our behalf and to assist us in providing the Service, including, without limitation, our email and SMS text messaging marketing partner, Klayvio; our customer relationship management (CRM) and e-commerce partner, Keap; our cloud storage platform, Microsoft Azure; our enterprise resource planning (ERP) partner, ColdLion; our hosting provider, Pantheon; our shipping partners, DHL, USPS, UPS, FedEx; and our digital signing software, PandaDoc.
We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third-party service providers and business partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third-party service providers and business partners to comply with Applicable Law and their respective privacy policies, and we take no responsibility for their privacy practices or compliance therewith.
To learn more about the respective privacy practices of our service providers, please visit their respective privacy policies:
6.3 In the Event of Merger, Sale, or Change of Control
Hemingway LTD may assign or transfer its rights and/or delegate its obligations under this Privacy Policy and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by Hemingway LTD, or is merged with or into Hemingway LTD, as part of a merger, acquisition, sale, or other change of control.
6.4 Other Disclosures
We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to:
Comply with legal process,
Enforce the Terms of Service, including investigations of potential violations thereof,
Detect, prevent, or otherwise address fraud or security issues, or
Protect the rights, property, or personal safety of Hemingway LTD, other Service users, and the public.
Retention of Personal Information
We will keep your Personal Information while you have an account with us or while we are providing services to you. Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:
To fulfill the purposes described above;
To respond to any questions, complaints, or claims made by you or on your behalf.
We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Policy.
Your Rights
8.1 Rights Relating to Personal Information
If you have an account on the Service, we provide access to—and the ability to edit or delete—certain categories of Personal Information through your account. You may also:
Delete browsing data and opt out of participation in future data collection from the current device;
Submit a request to Hemingway LTD to access, amend, correct, delete, export, object to, or restrict processing of your Personal Information, or withdraw consent (as applicable), by emailing info@collective222.net or mailing us at Hemingway LTD, [Insert Address Here].
You may also have a right to lodge a complaint with a regulatory agency. We encourage you to first reach out to us at info@hemingwayltd.com so we can try to address your concerns.
8.2 Email Notifications and Opt Out
We maintain a strict “no-spam” policy. Unless you opt out, you agree that we may contact you by email regarding administrative updates, newsletters, or promotional information related to the Service and/or Hemingway LTD. To opt out, follow the instructions in the communication or contact info@collective222.net.
8.3 SMS Text Messaging Notifications and Opt Out
By submitting your mobile number to Hemingway LTD via the Service, you consent to receive SMS notifications via our third-party partner (e.g., Klayvio). Message and data rates may apply. To stop receiving messages, text “STOP” to +1 (888) 463-3976. For help, text “HELP” or email info@collective222.net.
Data Security
We take reasonable precautions to protect your Personal Information and have implemented industry-standard administrative, technical, and physical safeguards. However, no method of transmission over the Internet or electronic storage is 100% secure.
Do Not Track Signals
At this time, the Service does not respond to Do Not Track signals due to lack of industry-wide standards.
Transfers from the EU, EEA, UK, or Switzerland
If you are located in the EU, EEA, UK, or Switzerland, your Personal Information may be transferred to and processed in the United States. We will take reasonable steps to ensure your information is treated securely in accordance with this Privacy Policy.
Notice to Residents of the EU, EEA, and UK
Under the GDPR, Hemingway LTD relies on several legal bases for processing Personal Information, including:
Consent
Contractual necessity
Legal obligations
Legitimate interests
Your rights include:
Withdraw consent
Access, rectify, or erase your Personal Information
Restrict or object to processing
Data portability
To exercise your rights, contact us at info@hemingwayltd.com. You may also contact your local data protection authority if we do not adequately resolve your concerns.
U.S. CONSUMER PRIVACY RIGHTS
Depending on your U.S. state of residence, you may have additional privacy rights with respect to your Personal Information. These rights may be granted to you pursuant to, respectively, the California Consumer Privacy Act; the California Privacy Rights Act; the Colorado Privacy Act; the Connecticut Personal Data Privacy and Online Monitoring Act; the Oregon Consumer Privacy Act; the Texas Data Privacy Act; the Utah Consumer Privacy Act; the Virginia Consumer Data Protection Act; the Montana Consumer Data Privacy Act; the Delaware Data Protection Act (effective January 1, 2025); the Iowa Data Protection Act (effective January 1, 2025); the Nebraska Data Privacy Act (effective January 1, 2025); the New Hampshire Privacy Act (effective January 1, 2025); the New Jersey Data Privacy Act (effective January 15, 2025); the Tennessee Information Protection Act (effective July 1, 2025); the Minnesota Consumer Data Privacy Act (effective July 31, 2025); and the Maryland Online Data Privacy Act (effective October 1, 2025) (collectively, as may be amended from time to time, “US Data Privacy Laws,” and together with the GDPR, “Data Privacy Laws”). You may have certain rights with respect to your Personal Information. For the purposes of this Section 13, Personal Information shall have the same meaning as “personal data” under US Data Privacy Laws.
13.1 Requests to Know
You have the right to request that we disclose:
The categories of Personal Information we have collected about you;
The categories of sources from which we have collected Personal Information about you;
Our use of the Personal Information we have collected about you;
The business or commercial purposes for selling or collecting Personal Information about you;
The categories of Personal Information sold, shared, or disclosed about you, as well as the categories – and, if you are a resident of Oregon or Colorado, the names – of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
The specific pieces of Personal Information collected about you for the twelve (12) months prior to the date of your request.
Our response to your request to know may be delivered electronically or by mail. We are not required to respond to more than two requests to know within a twelve (12)-month period.
13.2 Requests to Delete
You have the right to request that we delete any Personal Information we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
Complete the transaction for which the Personal Information was collected, provide a service you requested, or perform our contract with you;
Detect security incidents or illegal activity;
Debug to identify and repair errors;
Exercise free speech or comply with the law;
Engage in public interest research if deletion would hinder results and you have consented;
Enable internal uses reasonably aligned with expectations;
Comply with a legal obligation;
Or make other lawful and compatible internal uses.
13.3 Right to Opt Out of the Processing, Sale, or Sharing of Personal and/or Sensitive Personal Information
You have the right to opt out of the sale or sharing of your Personal and/or Sensitive Personal Information with third parties. We process such information only with your prior consent.
Additionally, you have the right to opt out of processing your Personal Information for purposes not aligned with those described in Section 5 of this Privacy Policy (“Purpose for Which We Use Personal Information”).
We will honor your request within fifteen (15) days of receipt. Any information collected in connection with your request will be used solely for processing that request. You may submit opt-out requests by emailing us at info@collective222.net.
13.4 Requests to Correct Inaccurate Personal Information
You have the right to request corrections to inaccurate Personal Information that we maintain. Upon a verifiable request, we will use commercially reasonable efforts to correct it.
13.5 Right to Opt Out of Profiling
You have the right to opt out of automated processing of your Personal Information when used to make legal or similarly significant decisions. Hemingway LTD does not currently engage in such profiling.
13.6 Right to Non-Discrimination
We will not discriminate against you for exercising your rights under US Data Privacy Laws. This includes:
Denying services;
Charging different prices or rates;
Providing a different level or quality of service;
Suggesting different pricing or service levels.
13.7 Authorized Agents
You may authorize someone to act on your behalf. They must provide written permission, and we may require verification of your identity. A power of attorney may also be used to submit requests on your behalf.
13.8 Methods for Submitting Consumer Requests and Our Response
To submit a request under US Data Privacy Laws, please contact Hemingway LTD’s Privacy Officer by email at info@collective222.net or by mail at:
Hemingway LTD
[Insert mailing address here]
We reserve the right to verify all requests. Additional information may be required to confirm your identity, used solely for that purpose. We will acknowledge your request within ten (10) days and respond within forty-five (45) days.
If you are a resident of Oregon or Texas, you may appeal any denial within 45 days of receipt by contacting us at info@collective222.net.
Residents of Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Tennessee, Texas, or Virginia may also appeal a denied request by emailing info@collective222.net within 45 days. We will respond within 45–60 days, depending on your state.
If your appeal is denied:
Connecticut: https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page
Maryland: https://www.marylandattorneygeneral.gov/Pages/CPD/Complaint.aspx
13.9 Categories of Personal Information Sold or Shared in the Last 12 Months
We have not sold or shared any categories of Personal Information in the past twelve (12) months.
13.10 Categories of Personal Information Disclosed for Business Purposes in the Last 12 Months
We have disclosed the following categories of Personal Information:
Identifiers: first and last name, email address, telephone number, mailing address, and geographic location.
13.11 Shine the Light Law
California’s “Shine the Light” law allows residents to request a list of third parties to whom their Personal Information was disclosed for direct marketing. However, if a business offers an opt-out for such sharing and discloses this policy, it is not required to provide the list.
We only use your Personal Information for marketing if you consent and offer you the ability to opt out at any time by emailing info@collective222.net.
Contact Us
If you have any questions about this Privacy Policy or your rights, please contact us at:
Hemingway LTD
Email: info@collective222.net
Mailing Address: 110 E 59th St, New York, NY 10022
© 2024 Hemingway LTD. All rights reserved.