Privacy Policy
1. Introduction and Scope
1.1 This Privacy Policy (this “Policy”) describes how Life Season Letters, LLC, a Tennessee limited liability company (the “Company,” “we,” “us,” or “our”), collects, uses, discloses, and protects Personal Information in connection with its website located at LifeSeasonLetters.com, its written-companionship subscription products, its gift subscriptions, its related marketing communications, and any related online services (collectively, the “Services”).
1.2 As used in this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information does not include information that has been aggregated or de-identified such that it can no longer reasonably be associated with an individual. The terms “you” and “your” refer to the individual who accesses or uses the Services.
1.3 This Policy applies to all users of the Services, including website visitors, recipients of free materials, subscribers to paid subscriptions, purchasers of gift subscriptions, recipients of gift subscriptions, participants in any invitation-based program the Company may offer, and any individual who communicates with the Company.
1.4 By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, you should not access or use the Services. Your use of the Services is also governed by the Company’s Terms of Service and Refunds and Cancellations Policy.
2. Information We Collect
The Company collects the categories of Personal Information described in this Section from three sources: information you provide directly, information collected automatically through your use of the Services, and information received from third parties.
2.1 Information You Provide. The Company collects Personal Information that you provide in connection with the Services, including:
- (a) Account Information: your name and email address. The Services use magic-link authentication; the Company does not use or store account passwords;
- (b) Subscription and Delivery Information: the subscription category or categories you select, your mailing address, your telephone number, the time zone in which you register, and the month and day of your birth (the Company does not collect your year of birth);
- (c) Payment Information: payment card and billing information, which is collected and processed by the Company’s third-party payment processor. The Company does not collect or store full payment card numbers or financial account credentials, and receives from its processor only limited transaction details, such as card type, the last four digits of the card, billing postal code, and confirmation of payment;
- (d) Gift Information: where you purchase a gift subscription, the recipient’s name, email address, and telephone number, and any message you elect to include, each of which you represent you are authorized to provide;
- (e) Communications: the contents of the messages, forms, requests, and other communications you submit to the Company, together with the Company’s records relating thereto. Where you contact the Company by telephone, the Company may monitor or record the call for quality, training, and recordkeeping purposes, and will provide notice where required by law;
- (f) Testimonials and Submissions: any review, testimonial, or other content you submit, together with the name or initials you provide to us. By submitting such content, you grant the Company permission to publish it, in whole or in part, together with the name or initials you provide, subject to your right to request removal; and
- (g) Survey Responses: information you provide in response to surveys or requests for feedback.
2.2 Information Collected Automatically. When you access the Services, the Company and its service providers automatically collect certain information, including:
- (a) Device and Usage Data: your IP address, approximate location derived from your IP address, browser type, device type, operating system, referring source, the pages and content accessed, and the dates and times of access;
- (b) Cookies and Similar Technologies, as described in Section 4; and
- (c) Email Engagement Data: information regarding the delivery of, and interaction with, the Company’s email communications, including whether a communication was delivered, opened, or clicked.
2.3 Information from Third Parties. The Company receives information from the service providers that support the Services, including confirmation of payment from its payment processor, delivery and engagement information from its email service provider, aggregate usage information from its analytics provider, and information regarding the source or marketing channel through which you accessed the Services.
2.4 Consumer Health Information. The Company does not collect health information. To provide the Services, the Company collects only the information necessary to process transactions, maintain its email list, and deliver its subscription materials, as described in this Section. The Company does not request or collect medical records, diagnoses, symptoms, treatment information, or other health information, and the subscription category you select constitutes a product preference and not a health record. Certain state laws, including the Washington My Health My Data Act, Nevada Senate Bill 370, and the Connecticut Data Privacy Act, afford heightened protection to information defined as “consumer health data.” Because the Company does not collect such information, these provisions do not presently apply to the Company’s collection of Personal Information. In the event the Company later collects information that constitutes consumer health data, the Company will comply with the applicable requirements of such laws before doing so.
2.5 Sensitive and Unsolicited Information. The Company requests that you not submit sensitive Personal Information that the Company has not requested, including medical records, diagnoses, details of family or legal proceedings, financial account numbers, and similar information. The subscription category you select and the fact of your subscription are treated as confidential and are used solely to provide the Services and to operate the Company’s business. If you elect to provide unsolicited information, you do so voluntarily, and the Company will handle such information in accordance with this Policy.
3. How We Use Information
The Company uses Personal Information for the following purposes:
- (a) to provide, operate, maintain, personalize, and deliver the Services, including the delivery of subscription materials and requested communications;
- (b) to create and administer accounts and to process subscriptions, gift subscriptions, renewals, and refunds;
- (c) to process payments and maintain billing, accounting, and tax records;
- (d) to send transactional and administrative communications, including receipts, delivery notices, renewal and billing notices, sign-in links, and security notices, by email;
- (e) to send optional communications that you have requested, and to administer your communication preferences;
- (f) to respond to inquiries and provide customer support;
- (g) to analyze, improve, develop, and maintain the Services;
- (h) to detect, prevent, investigate, and respond to fraud, abuse, security incidents, and other unlawful or harmful activity;
- (i) to protect the rights, property, and safety of the Company, its subscribers, its personnel, and the public;
- (j) to advertise and market the Services, as described in Section 4; and
- (k) to comply with legal obligations and to establish, exercise, or defend legal claims.
The Company will not use Personal Information for materially different or incompatible purposes without providing notice.
4. Cookies, Analytics, and Advertising Technologies
4.1 The Company and its service providers use cookies, pixels, tags, and similar technologies (collectively, “Cookies”) in connection with the Services. These technologies serve the following functions:
- (a) Strictly Necessary: to enable core website functionality, maintain sessions, and provide security;
- (b) Preference: to retain user selections and settings;
- (c) Analytics: to evaluate, in the aggregate, how the Services are accessed and used; and
- (d) Advertising: to measure the performance of the Company’s advertising and to present the Company’s advertisements to prospective subscribers, including through third-party platforms such as Meta and Pinterest. These technologies may transmit limited information, including online identifiers and activity on the Services, to such platforms.
4.2 Cookie Preferences. The Company provides a cookie preference tool on the website that permits you to accept all Cookies, reject all non-essential Cookies, or accept only strictly necessary Cookies. You may also manage Cookies through your browser settings. Certain features of the Services may not function properly if strictly necessary Cookies are disabled.
4.3 Global Privacy Control. Because there is no uniform industry standard for “Do Not Track” signals, the Company responds to the Global Privacy Control (“GPC”) signal. The Company treats a valid GPC signal as a request to opt out of the sharing of Personal Information for advertising purposes, as described in Section 5.
5. How We Disclose Information
The Company does not sell Personal Information in exchange for monetary consideration, and does not disclose Personal Information to third parties for those third parties’ own independent use. The Company discloses Personal Information only as described in this Section.
5.1 Service Providers. The Company discloses Personal Information to service providers that perform functions on the Company’s behalf, including payment processing, email delivery, website hosting, and analytics. Such service providers are permitted to access Personal Information only as necessary to perform their functions, are bound by contractual confidentiality and security obligations, and are prohibited from using Personal Information for their own purposes.
5.2 Advertising Partners. The Company uses the Meta Pixel and the Meta Conversions API, and the Pinterest Tag, to measure the effectiveness of its advertising and to present advertisements on Facebook, Instagram, and Pinterest. In connection with these activities, the Company may disclose the following categories of information to Meta Platforms, Inc. and Pinterest, Inc.:
- (a) hashed email address and name, where provided by you;
- (b) the pages you viewed and the actions you took on the Services, including page views, registrations, and purchases; and
- (c) device identifiers, including IP address and browser information.
This information is transmitted through a browser-based tag and through a server-to-server connection. These platforms may use this information to measure advertising performance and, where permitted, to target and optimize advertising. Each platform’s use of this information is governed by its own privacy policy, available at facebook.com/privacy/policy and policy.pinterest.com/privacy-policy.
Certain state privacy laws define the terms “sale” and “sharing” broadly, and the Company’s disclosure of hashed identifiers and browsing activity to these platforms for cross-context behavioral advertising may constitute a “sale” or “sharing” of Personal Information under those laws, notwithstanding that no monetary consideration is exchanged and that the Company does not disclose Personal Information for any third party’s own independent use. You have the right to opt out of this sharing at any time, as described in Sections 6.3 and 7. The Company does not disclose customer or subscriber lists to advertising platforms.
5.3 Legal and Safety. The Company may disclose Personal Information where it believes in good faith that disclosure is necessary to (a) comply with applicable law or valid legal process, including a subpoena, court order, or governmental request; (b) cooperate with a lawful investigation; (c) establish, exercise, or defend legal claims; (d) enforce the Company’s Terms of Service or Refunds and Cancellations Policy; (e) prevent fraud or a security threat; or (f) protect the rights, property, or safety of any person. In such circumstances, the Company discloses only the information reasonably necessary.
5.4 Business Transfers. In the event of a merger, acquisition, financing, reorganization, sale of assets, or similar transaction, Personal Information may be transferred as part of that transaction. The Company will require that any recipient of such Personal Information be bound by this Policy or by a privacy policy that is at least as protective, and will provide notice before any Personal Information becomes subject to a materially different privacy policy.
5.5 Disclosures With Consent. The Company discloses Personal Information for purposes other than those described in this Section only with your consent, which you may withdraw at any time.
5.6 Aggregated and De-Identified Information. The Company may use and disclose aggregated or de-identified information, which does not constitute Personal Information, for any lawful purpose. The Company will not attempt to re-identify such information.
6. Your Choices
6.1 Email Communications. Optional email communications are subject to a double opt-in confirmation. You may modify your communication preferences or unsubscribe from optional communications at any time through your account or the unsubscribe mechanism contained in such communications.
6.2 Text Messages. The Company does not currently offer text-message (SMS) communications and does not send marketing text messages. If the Company offers an optional text-message service in the future, it will be provided only on an opt-in basis, with the required disclosures presented at the time of sign-up, and enrollment will not be a condition of purchasing any product or service.
6.3 Advertising Choices. You may opt out of the advertising activities described in Section 5.2, and the associated sharing of Personal Information, by (a) using the “Do Not Sell or Share My Personal Information” mechanism (also presented as “Your Privacy Choices”) made available on the website; (b) enabling a Global Privacy Control signal, which the Company honors; or (c) contacting the Company at support@LifeSeasonLetters.com. You may also manage advertising Cookies through the cookie preference tool and adjust advertising settings directly with the applicable platforms.
6.4 Account Information. You may review and update your account information, including your name, contact information, and communication preferences, through your account.
6.5 No Financial Incentives. The Company does not offer financial incentives in exchange for the collection, sale, or sharing of Personal Information.
7. Your Privacy Rights
7.1 Rights for All Users. Subject to applicable law, you may request to access, correct, update, or delete your Personal Information, and you may withdraw consent to optional communications, by contacting the Company as described in Section 14. The Company will respond as required by applicable law. Certain information may be retained as permitted or required by law, including for the purposes described in Sections 5.3 and 8.
7.2 California Residents. If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), provides the following rights:
- (a) the right to know and access the categories and specific pieces of Personal Information the Company has collected, the categories of sources, the business or commercial purposes for collection, and the categories of third parties to whom Personal Information is disclosed;
- (b) the right to request deletion of Personal Information, subject to statutory exceptions;
- (c) the right to request correction of inaccurate Personal Information;
- (d) the right to opt out of the “sale” or “sharing” of Personal Information, which you may exercise as described in Section 6.3; and
- (e) the right not to receive discriminatory treatment for exercising these rights.
The categories of Personal Information the Company collects, the sources of that information, the purposes for its use, and the categories of recipients are described in Sections 2, 3, and 5. As described in Section 5.2, the Company engages in advertising activities that may constitute a “sale” or “sharing” under the CCPA, and you may opt out as described in Section 6.3. The Company does not use or disclose sensitive personal information, as defined under the CCPA, for purposes that would give rise to the right to limit its use. Consistent with California’s “Shine the Light” law, the Company does not disclose Personal Information to third parties for those third parties’ own direct marketing purposes. You may exercise your rights through an authorized agent, and the Company may verify your identity before responding.
7.3 Residents of Other States. If you are a resident of a state that has enacted a comprehensive consumer privacy law, including Virginia, Colorado, Connecticut, Utah, Texas, or Oregon, you may have the rights to access, correct, delete, and obtain a portable copy of your Personal Information, and to opt out of targeted advertising, the sale of Personal Information, and certain profiling. The Company does not sell Personal Information for monetary consideration or for any third party’s own use, and does not engage in profiling that produces legal or similarly significant effects. The Company engages in targeted advertising as described in Section 5.2, and you may opt out as described in Section 6.3. Where provided by law, you may appeal a decision regarding your request by contacting the Company as described in Section 14, and if your appeal is denied, you may contact your state attorney general.
7.4 Nevada Residents. Nevada law permits Nevada residents to direct certain businesses not to sell covered information. The Company does not sell Personal Information for monetary consideration. You may submit a request by contacting the Company as described in Section 14.
7.5 Exercising Your Rights. To exercise the rights described in this Section, contact the Company at support@LifeSeasonLetters.com. The Company may request information sufficient to verify your identity before responding. The Company does not charge a fee for a verifiable request except as permitted by law, and will not discriminate against you for exercising your rights.
8. Data Retention
The Company retains Personal Information for as long as necessary to fulfill the purposes described in this Policy, after which it deletes or de-identifies such information. Retention periods are determined by reference to the following criteria:
- (a) account and subscription information is retained for the duration of the account and for a reasonable period thereafter;
- (b) payment, billing, and tax records are retained as required to satisfy legal, tax, and accounting obligations;
- (c) communications and support records are retained for a reasonable period following resolution;
- (d) information necessary for legal or safety purposes is retained for as long as reasonably necessary to resolve disputes, prevent fraud or abuse, and establish, exercise, or defend legal claims; and
- (e) aggregated and de-identified information may be retained indefinitely.
Residual copies of information may persist in backup systems for a limited period and are removed in the ordinary course of business.
9. Data Security
9.1 The Company maintains administrative, technical, and physical safeguards designed to protect Personal Information against loss, misuse, and unauthorized access, disclosure, alteration, and destruction. The Services employ industry-standard encryption (SSL/TLS) to protect information transmitted between your device and the Company. Payment transactions are processed by a PCI-DSS-compliant payment processor, and full payment card information is not stored on the Company’s systems. The Services use magic-link authentication rather than stored passwords, so no account passwords are collected or stored. Access to Personal Information is restricted to personnel who require such access to perform their duties.
9.2 All personnel and independent contractors who perform services for the Company are required to execute confidentiality agreements pursuant to which they agree not to disclose information to which they have access. The Company will pursue all available legal remedies against any person who violates such an agreement.
9.3 You are responsible for maintaining the confidentiality of your account credentials and for notifying the Company promptly at support@LifeSeasonLetters.com of any unauthorized use of your account. No method of transmission or storage is completely secure, and the Company cannot guarantee absolute security. In the event of a security incident affecting Personal Information, the Company will provide notice to affected individuals and to regulatory authorities as required by applicable law.
10. Children’s Privacy
The Services are intended for adults. You must be at least eighteen (18) years of age to access the Services, create an account, or purchase a subscription. The Company does not knowingly collect Personal Information from any individual under eighteen (18) years of age. If the Company learns that it has collected Personal Information from an individual under eighteen (18), it will delete that information. If you believe that an individual under eighteen (18) has provided Personal Information to the Company, please contact the Company at support@LifeSeasonLetters.com.
11. International Users
The Services are directed to residents of the United States, and the Company operates in the United States. If you access the Services from outside the United States, you acknowledge that your information will be transferred to, processed, and stored in the United States, where data protection laws may differ from those of your jurisdiction. The Company may expand the Services to additional countries and, in that event, will comply with the applicable privacy and data protection laws of those countries.
12. Third-Party Websites and Services
The Services may contain links to, and may rely upon, websites and services operated by third parties, including the Company’s payment processor and email service provider. The Company is not responsible for the privacy practices of such third parties, and this Policy does not apply to their processing of your information. You should review the privacy policies of such third parties before providing information to them.
13. Changes to This Privacy Policy
The Company may amend this Policy from time to time. The Company will post the amended Policy with a revised “Last Updated” date and, where the changes are material, will provide additional notice as appropriate. Your continued use of the Services following the effective date of an amended Policy constitutes acceptance of the amended Policy.
14. Contact Information
Questions regarding this Policy, and requests to exercise privacy rights, may be directed to the Company as follows:
Life Season Letters, LLC
Email: support@LifeSeasonLetters.com
Telephone: 760-492-3586
Mailing Address: 118 Public Square, Suite E, Shelbyville, TN 37160