PRIVACY POLICY

Effective Date: September 6, 2022.  

1. Introduction and Overview.

This Privacy Policy provides a comprehensive description of how SGA Productions LLC d/b/a SoMad (“SoMad,” “we,” “our,” or “us”) collects, uses, and discloses information about you as well as your rights and choices regarding such information. It applies to any online location controlled by us that links to this Privacy Policy (the “Service”). 

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. 

2. Information Collection.

A. Information You Provide.

We collect information about you when you use the Service, including information you provide when you access our content, make a purchase, or contact us. The categories of information we collect include:

• Contact Data, including your first and last name, email address, postal address, and phone number.

• Demographic Data, including your country. 

• Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.

• Content, including content within any messages you send to us (such as feedback or questions to customer support).

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.  

B. Information Collected Automatically.

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:

• Service Use Data, including data about features you use, pages you visit, emails you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.

• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.

• Location Data, including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level).

The types of tracking technologies we use to automatically collect this information include:

• Cookies, which are small data files stored on your browser that save data about your visit. Cookies often include a unique identifier (e.g., cookie #123). We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and expire on a set expiration date or when they are deleted manually. 

• Pixels (also known as web beacons), which is code embedded in a service that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a service that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser, or collect other information about your visit. 

• Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, see the “Analytics” and “Your Rights and Choices” sections below.

C. Information from Other Sources.

We also collect information from other sources. The categories of sources from which we collect information include: 

• Social media platforms with which you interact.

• Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.

• Publicly-available sources, including data in the public domain.

3. Use of Information.

We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:

• Providing the Service to you.

• Preventing and addressing fraud, breach of policies or terms, or threats or harm. 

• Understanding trends, usage, and activities, including through tracking technologies or surveys, to make business and marketing decisions.

• Communicating with you about updates, security alerts, changes to policies, and other transactional messages.

• Personalizing your experience to show you content we believe you will find interesting. 

• Engaging in direct marketing, promotional communications, and non-personalized advertising. 

• Fulfilling any purpose at your direction.

• With notice to you and your consent.

Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4. Disclosure of Information.

We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include: 

• Service Providers and Contractors. We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. To the extent required by law, we contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.

• Analytics. We disclose information to vendors and other parties for analytics  related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on analytics, see the “Analytics” section below. 

• Affiliates. We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes.

• Partners. We disclose information to our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities. 

• Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we disclose information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.

• Merger or Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business. 

• Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else. 

• Facilitating Requests. We disclose information where you direct us to disclose the information. 

• Consent. We disclose information with notice to you and your consent. 

Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.

5. Other Parties.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service. 

Some examples include:

• Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. 

• Brand Pages and Messaging. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand pages) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with SoMad in a tweet or post), we may use your reference on or in connection with our Service.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Analytics.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. 

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

7. Your Rights and Choices. 

A. Tracking Technology Management.

• Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. 

• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly. 

B. Analytics Management.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout.  

Please note that the above opt out only applies to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities. 

C. Communications.

E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at hello@somad.nyc with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.

Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.  

8. Children.

The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at hello@somad.nyc. We will delete the personal information in accordance with COPPA. 

9. Data Security.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

10. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, disclosure, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. Where required by applicable law, we will provide appropriate safeguards for data transfers, such as through use of standard contractual clauses.

11. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.  

12. Contact Us.

If you have any questions about our data practices, or experience any difficulty accessing the information in this Privacy Policy, please contact us:

By email:

hello@somad.nyc

By mail:

SoMad, 34 E 23rd St, 4th Floor, New York, NY 10010