Privacy Policy

Effective Date: January 1, 2023

1 .Introduction

You have arrived at a website operated by Hothouse, Inc. or our affiliates (“Hothouse,” “we”, “our” or “us”). Welcome to the un-agency! We answer only to our clients and each other—instead of shareholders or holding companies. That independence combined with responsive capabilities, flexible workflows, and an independent structure empower us to create and deliver marketing content at-scale with a ferocity and velocity like no other. At Hothouse, we take your privacy very seriously. This Privacy Notice (“Notice”) describes the types of personal information (as defined below) that we collect, how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust.

2. Scope

This Notice applies when you use or access the website, and its subdomains or portals (the “Site”); or otherwise provide Personal Information or interact with us online or in-person. For the purpose of this Notice, "Personal Information" means any personal information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all of the above as “Services.” Our Services are used by our clients (“Clients”), individuals who enter our Clients’ contests and sweepstakes (“Sweepstakes Contestants”), individuals who visit our Site (“Site Visitors”) and individuals applying for employment with Hothouse (“Employment Applicants”). By using the Services, you agree to our Terms of Service. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it. If you have any questions about this Privacy Notice, please contact us using the information in the Contact Us section below.

3. What Information We Collect

This section describes what information we collect from you through our Site or Services. We may receive information (including Personal Information) in the following ways:

Information That You Provide to Us

As you interact with our Site or Services such as when you contact us, join our mailing list or apply for a job with us, we may collect the following Personal Information via webforms or inputs/uploads on our Site, and through telephone calls, letters, emails and other communications with you:

Site Visitors
  • Contact information such as your first and last name, email address, job title, home or business address, telephone numbers, mobile numbers.
Clients
  • Contact information such as your first and last name, job title, email address, business address, shipping address, telephone numbers, mobile numbers; and
  • Financial information such as your business credit card or debit card number, bank account information.
Sweepstakes Contestants
  • Contact information such as your first and last name, user name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
  • Identifiers such as data of birth;
  • Social media account information; and
  • Other information that could reasonably be used to identify you personally.
  • Note: Hothouse conducts contests and sweepstakes on behalf of and at the direction of our Clients. Links to the rules, privacy policies, and terms specific to these contest/sweepstakes are available on the respective entry sites or printed entry mechanisms. For information on what Personal Information our Clients collect from you or how our Clients use that information, please refer to these links or contact the Client directly.
Employment Applicants
  • Contact information such as your first and last name, email address, home or business address, shipping address, telephone numbers, mobile numbers;
  • Your current or past employment or educational information;
  • Relevant licenses and certifications; and/or
  • Other information that could reasonably be used to identify you personally.

Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Site or Services.

Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:

  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Site that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
  • Your Device characteristics;
  • Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and
  • Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

Information Collected from Third Parties

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Hothouse from third parties. We might also provide links to facilitate sending a communication from the Site, or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Hothouse. Hothouse does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

4. How We Use Your Information

We use your information for business and commercial purposes, including to use or browse the Site, to offer our Services, to provide you with customer service, to prevent security and fraud, to provide marketing information about our products and services, and to perform website analytics.

We may use the information we collect about you in a variety of ways, including to:

To Provide Our Services

We process certain Personal Information when you access or use our services, including to:

  • facilitate the functionality of our Site;
  • solicit, track, award and fulfill incentives for successful completion of user affiliate commitments;
  • verify your eligibility and identity and fulfill prizing awards for sweepstakes and contests that we administer on behalf of our Clients; and
  • customize experiences and personalization when you are on our Site.

To Communicate with You

We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

  • communicate with you about our Services, accounts, programs, contests, and sweepstakes;
  • respond to your customer service inquiries and requests for information;
  • send you personalized promotions, content, and special offers;
  • communicate with you about our brands, products, events, or other promotional purposes;
  • implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and

For Improvement of Our Site or Services

We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

  • maintain, improve, and analyze our Site or Services; and
  • detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

  • maintain appropriate records for internal administrative purposes; and
  • comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we use your Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

To Evaluate Your Application for Employment

We may use your information to evaluate your application for employment or administer employment benefits.

With Your Consent

We may process certain Personal Information in order to fulfill any other business or commercial purposes at your direction or with your consent.

5. Use of Cookies

We use cookies (a small text file sent by your computer each time you visit our site) and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options. We may use the following types of cookies:

  • Strictly necessary cookies. These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site. Cookies that allow web shops to hold your items in your cart while you are shopping online are an example of strictly necessary cookies. While it is not required to obtain consent for these cookies, what they do and why they are necessary should be explained to the user.
  • Functionality cookies. Also known as “preference cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your user name and password are so you can automatically log in.
  • Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
  • Advertising cookies. Hothouse does not gather information utilizing advertising cookies on our site.

Types of Cookies we use
Manage cookie preferences: Cookie Settings

You can change your cookie preferences any time by clicking the above button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away. We might also use pixel tags, which are small graphic files that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address of the device from which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements. Other data technologies may be used that collect comparable information for security and fraud detection purposes. If you have any questions about cookies or to generally find out more about cookies, the All About Cookies website is a trusted resource.

6. Your Choices

Cookies

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.

Do Not Track

Your browser may offer you a “Do Not Track” (“DNT”) option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. There is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. Learn more about Do Not Track here.

Global Privacy Control

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. In certain territories, when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law. This Universal Opt-Out Mechanism allows consumers to exercise any and all opt-out rights available to you under state laws.

Communication Preferences

With your consent, Hothouse communicates with you via a variety of print and digital media. To help us make e-mails more useful and interesting, we use pixels that enable us to see if you open e-mails from us, if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with Hothouse — or to opt out of communications entirely — please unsubscribe at the bottom of our emails or contact us at privacy@hothouseinc.com.

Analytics

We use Google Analytics to help us understand how our customers use the Site. Read more about how Google uses your Personal Information here and opt-out of Google Analytics here.

7. How We Share Your Information

Services Providers

We share your Personal Information with our third-party service providers who provide services such as website hosting, data analysis, information technology, customer service, email delivery, auditing, event planning and other services.

Other

Aside from the instances described above, we may share your Personal Information:

  • to comply with the law;
  • to respond to claims or comply with legal process served on Hothouse (e.g., a lawful subpoena, warrant, or court order);
  • to enforce or apply our policies or agreements;
  • to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
  • in connection with a business transfer, sale, liquidation, or merger;
  • if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
  • to other parties only with your consent.

8. Third Party Links

Out Site may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.

9. International Transfers of Personal Information

The Site is operated and targeted toward audiences in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Site and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.

10. Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us using the information in the Contact Us section below.

11. Your California Privacy Rights

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Reform Act (“CPRA”). If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information we have collected about you;
  • The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
  • The categories of Personal Information about you that we disclosed for a business purpose.
  • The categories of sensitive personal information to be collected and the purposes for which the categories of sensitive personal information are collected or used and whether such information is sold or shared.

Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Right to Correct Personal Information

You have the right to request that we correct any inaccurate information that we maintain about you.

Right to Opt-Out

You have the right to opt out of the sale or sharing of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please email privacy@hothouseinc.com

Right to Limit the Use or Disclosure of Sensitive Personal Information

Companies who collect, use, and disclose your sensitive personal information for purposes other than to provide you with goods or services are required to provide you with the right to limit the use and disclosure of your sensitive personal information. We use sensitive personal information on behalf of our Clients as a part of our Service Provider scope. To exercise this right, please email privacy@hothouseinc.com.

Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

  • Denying you goods or services;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of goods or services; or
  • Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

This includes the right of current and prospective employees not to be retaliated against for the exercise of their CCPA rights.

However, as permitted by the CCPA, we may offer you certain financial incentives. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may withdraw at any time.

Personal Information We Collect about California Consumers

We collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:

Category of Personal Information Collected Collected (Yes/No) Sources of Personal Information Collected Business or Commercial Purpose for Collection
Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above. Yes You

Automatically

Third Parties

To provide our products and Services

To provide information you requested

To improve our products and Services

To identify potential customers

To market our products and Services

For verifying identity

For fraud prevention purposes

To process payments

To comply with law

To offer employment, to provide insurance and benefits, for background checks

The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above. Yes You

Automatically

Third Parties

To provide our products and Services

To provide information you requested

To improve our products and Services

To identify potential clients

To market our products and Services

For verifying identity

For fraud prevention purposes

To process payments

To comply with law

To manage payroll and provide and administer employee benefits

Characteristics of protected classifications under California or federal law list any of these that you collect: race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. No N/A N/A
Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time. Yes You

Automatically

Third Parties

To provide our products and Services

To market our products and Services

To improve our products and Services

To provide information you requested

To comply with law

Biometric Information. No N/A N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, mobile apps, or Hothouse pages or accounts on any third-party social media platforms. Yes Automatically To provide our products and services

To market our products and services

To improve our products and services (e.g., usage pattern data)

To track employee actions for internal reports and information security purposes

Geolocation data. No N/A To market our products and services

For detecting security incidents and protecting our Site

Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above. No N/A N/A
Professional or employment-related information. Yes You

Automatically

Third Parties

To provide our products and Services

 

To offer employment, to provide insurance and benefits, for background checks

Education information. No N/A N/A
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on our websites and mobile apps or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. Yes Third Parties To provide our products and services

To market our products and services

To improve our products and services

For detecting security incidents and protecting our Site

Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number. Yes You N/A

How to Exercise Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

  • Submitting a request to privacy@hothouseinc.com
  • Calling us at 404-223-5100
  • Mailing us at: 621 North Ave NE, Suite C-200, Atlanta, GA 30308

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. This might include asking for your email address. If you use an authorized agent to exercise your rights, we may require proof of written authorization you have given the authorized agent to make the request on your behalf. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time.

Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us using the information in the Contact Us section below.

12. Your Virginia Privacy Rights

If you are a resident of Virginia, you have the right under the Virginia Consumer Data Protection Act, upon a verified request, to:

  • To confirm whether or not a controller is processing your personal data and to access such personal data;
  • To correct inaccuracies in your personal data;
  • To delete your personal data;
  • To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
  • To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

To exercise these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Contact Us section below:

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Virginia Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Virginia resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period. If we decline to take action on your request, residents of Virginia can appeal our decision by submitting an email to privacy@hothouseinc.com entitled “Virginia Privacy Rights Appeal” and we will review your request and respond with a written explanation of the reasons for our decision. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.

13. Children’s Privacy

On occasion we may run a contest or sweepstakes on behalf of a client. Under those circumstances Hothouse ensures full compliance with COPPA (Children's Online Privacy Protection Act) by taking measures such as requiring parental consent for contestants under the age of 13 and requiring an affirmative opt-in check box for communications.

14. Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice's effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Site and/or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.

15. Contact Us

If you have any questions or suggestions regarding this Privacy Notice, please contact us at:

Hothouse, Inc.
621 North Ave NE, Suite C-200
Atlanta, GA 30308

Email: privacy@hothouseinc.com
Contact number: 404-223-5100