Privacy Policy
1. Introduction & About Us
Cremdeal ("we", "us", or "our") operates cremdeal.com and related services (the "Service"). Our principal place of business is located at 2200 Ross Avenue, Suite 4100, Dallas, TX 75202.
We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information, with specific disclosures required by the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), effective January 1, 2023.
For privacy inquiries, contact us at:
Email: [email protected]
Phone: +1 (214) 225-6613
Postal: Privacy Team, Cremdeal, 2200 Ross Avenue, Suite 4100, Dallas, TX 75202
2. Categories of Personal Information We Collect
In the past 12 months, we have collected the following categories of personal information as defined by the CCPA:
| CCPA Category | Examples | Collected? | Sources |
|---|---|---|---|
| A. Identifiers | Real name, alias, email address, IP address, account name, unique personal identifiers | Yes | You directly; automatically |
| B. Personal Records (Cal. Civ. Code § 1798.80) | Name, address, telephone number, financial information | Yes | You directly |
| C. Protected Classifications | Age (40+), race, gender, veteran status (if applicable) | Limited / Only if voluntarily provided | You directly (optional) |
| D. Commercial Information | Products/services purchased, purchase history, preferences | Yes | You directly; transactions |
| E. Biometric Information | Fingerprints, face/voice recognition data | No | — |
| F. Internet / Electronic Activity | Browsing history on our site, search history, interaction with our ads/content | Yes | Automatically via cookies/analytics |
| G. Geolocation Data | Physical location derived from IP address (city/country level) | Yes (approximate) | Automatically |
| H. Sensory Data | Audio, electronic, visual, thermal, or olfactory information | Only if you contact us by phone (call recordings) | You directly (if applicable) |
| I. Professional / Employment Info | Job title, employer, professional background | Only if voluntarily provided | You directly |
| J. Education Information | Education history not covered by FERPA | No | — |
| K. Inferences | Profile reflecting preferences, characteristics, predispositions, behaviour | Yes (for personalisation) | Derived from categories above |
| L. Sensitive Personal Information | Account log-in + password (security credentials) | Yes (credentials only) | You directly (account creation) |
2.1 Sources of Personal Information
- Directly from you — forms, account registration, purchases, support requests, surveys;
- Automatically — cookies, web beacons, server logs when you use our Service;
- Third parties — analytics providers, advertising partners, social media platforms (where you choose to interact with us via those platforms), data enrichment providers.
3. Business & Commercial Purposes for Collection & Use
We collect and use personal information for the following business and commercial purposes:
- Providing, maintaining, and improving our products and services;
- Processing transactions and managing accounts;
- Fulfilling orders and delivering products;
- Sending transactional communications (receipts, account alerts, service notices);
- Providing customer support and responding to inquiries;
- Personalising your experience and content;
- Conducting analytics to understand how our Service is used;
- Sending marketing communications (where you have opted in or where permitted);
- Fraud prevention, security monitoring, and protecting legal rights;
- Complying with applicable laws, regulations, and legal process;
- Evaluating or conducting a merger, divestiture, or other business transaction;
- Advertising and marketing to you, including cross-context behavioural advertising.
4. Disclosure, Sale & Sharing of Personal Information
4.1 Categories Disclosed for Business Purposes
In the past 12 months, we have disclosed the following categories of personal information to service providers and contractors for business purposes:
- Identifiers (A) — to cloud hosting, email providers, analytics providers;
- Commercial information (D) — to payment processors, fulfilment partners;
- Internet / electronic activity (F) — to analytics and advertising platforms;
- Inferences (K) — to content personalisation platforms.
4.2 Sale & Sharing of Personal Information
Under the CCPA, "sale" includes exchanging personal information for money or other valuable consideration. "Sharing" includes disclosing personal information to third parties for cross-context behavioural advertising, even without monetary exchange.
| PI Category | Sold? | Shared for Cross-Context Behavioural Advertising? | Third-Party Recipients |
|---|---|---|---|
| Identifiers (A) | No | Yes (cookie IDs, IP) | Analytics, ad networks |
| Internet / Electronic Activity (F) | No | Yes (browsing behaviour) | Analytics, ad networks |
| Inferences (K) | No | Yes (interest segments) | Ad platforms |
| All other categories | No | No | — |
4.3 Do Not Sell or Share — Opt-Out
California residents have the right to opt out of the sale or sharing of their personal information at any time. To exercise this right:
- Click the link: Do Not Sell or Share My Personal Information
- Global Privacy Control (GPC): We honour GPC signals. If your browser transmits a GPC signal, we will treat it as an opt-out request for the sale/sharing of personal information for that browser session and, to the extent technically feasible, for your linked account.
- Email: [email protected] with subject "CCPA Opt-Out Request".
Once we receive your opt-out request, we will cease the sale or sharing of your personal information within 15 business days. You may opt back in to the sale of your personal information at any time by contacting us, but we will wait at least 12 months before asking you to reconsider.
4.4 Sensitive Personal Information
We collect only the following sensitive personal information (SPI) and use it solely for the purposes of providing our services:
- Account log-in credentials (username + hashed password) — used solely to authenticate your account;
We do not use or disclose sensitive personal information for purposes beyond those necessary to provide the Service. You may exercise the right to limit our use of sensitive personal information by contacting us at [email protected].
4.5 Financial Incentives
We may offer financial incentives (discounts, loyalty rewards) in exchange for personal information. These incentives have a reasonably proportionate relationship to the value of your personal information. Participation is voluntary and you may withdraw at any time.
5. Your California Privacy Rights
If you are a California resident, you have the following rights under the CCPA/CPRA:
Right to Know (CCPA)
Request disclosure of the categories and specific pieces of personal information we have collected about you, sources, business/commercial purposes, and third parties with whom we share it. You may request this up to twice per 12-month period.
Right to Delete (CCPA)
Request deletion of personal information we have collected, subject to certain exceptions (e.g., completing a transaction, security, legal obligations, free speech, research).
Right to Opt-Out of Sale/Sharing (CCPA)
Direct us not to sell or share your personal information with third parties for cross-context behavioural advertising. Use the opt-out link or honour GPC signals.
Right to Non-Discrimination (CCPA)
We will not discriminate against you for exercising your CCPA rights — no denial of goods/services, no different prices, no different quality unless the difference is reasonably related to the value of your data.
Right to Correct (CPRA)
Request correction of inaccurate personal information we maintain about you, taking into account the nature of the information and our purposes for processing it.
Right to Limit SPI Use (CPRA)
Direct us to limit our use and disclosure of sensitive personal information to what is necessary to perform the services you request.
5.1 How to Submit a Consumer Request
California residents may submit requests by:
- Email: [email protected] with subject "CCPA Privacy Request";
- Phone: +1 (214) 225-6613;
- Postal mail: Cremdeal, Attn: Privacy Team, 2200 Ross Avenue, Suite 4100, Dallas, TX 75202.
5.2 Verification of Requests
To protect your information, we must verify your identity before fulfilling a request. We will ask you to provide information that matches what we have on file. For sensitive requests, we may require a higher level of verification. We will not use information provided for verification beyond that purpose.
Authorised agents: You may designate an authorised agent to make a CCPA request on your behalf. We may require written proof of authorisation and may verify your identity directly.
5.3 Response Timeline
We will acknowledge your request within 10 business days and respond within 45 calendar days. If we need more time, we will notify you and may extend the response period by an additional 45 days.
6. Retention of Personal Information
We retain personal information for as long as necessary to fulfil the purposes described in this policy, to comply with our legal obligations, resolve disputes, and enforce our agreements. Our general retention periods are:
| Category | Retention Period |
|---|---|
| Account / identity data | Duration of account + 2 years after closure |
| Transaction / purchase history | 7 years (tax/legal compliance) |
| Customer support records | 3 years from last interaction |
| Marketing consent / opt-out records | Indefinitely (to honour your preference) |
| Analytics / usage data | 26 months |
| Security / fraud logs | 12 months |
7. Security of Personal Information
We implement reasonable and appropriate technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction, including encryption in transit (TLS) and at rest, access controls, and employee training. No system is 100% secure; please use strong passwords and notify us promptly of suspected unauthorized access.
8. Children's Privacy
We do not knowingly collect personal information from consumers under 16 years of age. If you believe we have collected personal information from a minor under 16, please contact us at [email protected] and we will delete it promptly. We do not sell or share the personal information of consumers we know to be under 16 without affirmative authorisation.
9. Privacy Rights for Other Jurisdictions
Residents of other U.S. states with comprehensive privacy laws (including Virginia — VCDPA, Colorado — CPA, Connecticut — CTDPA, Utah — UCPA, Texas — TDPSA, and others) may have similar rights. For more information about your state-specific rights, please contact us at [email protected].
10. Cookies & Online Tracking
We and our partners use cookies, web beacons, pixels, and similar tracking technologies to collect internet/electronic activity data. Some of this data is used for cross-context behavioural advertising, which constitutes "sharing" under the CCPA. You may opt out by:
- Using our Cookie Policy settings;
- Clicking Do Not Sell or Share My Personal Information;
- Enabling the Global Privacy Control (GPC) in your browser.
See our Cookie Policy for full details.
11. Changes to This Privacy Policy
We may update this Privacy Policy as required by changes in law or our practices. When we make material changes, we will update the "Last updated" date and provide appropriate notice. We encourage you to review this policy periodically.
12. Contact Us
For questions, concerns, or to exercise your privacy rights:
- Company: Cremdeal
- Email: [email protected]
- Phone: +1 (214) 225-6613
- Address: 2200 Ross Avenue, Suite 4100, Dallas, TX 75202
- Do Not Sell / Opt-Out: cremdeal.com/do-not-sell