When you use the Site, we collect the following types of Information:
“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as [state the type of information collected]. In the European Economic Area (“EEA”), Personal Data includes an identification number, location information, and/or an online identifier.
Non-Personal Data does not identify you, but provides insights regarding your use of the Site(s). For example, we collect information about your use of the Site, including but not limited to [state the type of information collected].
You may be given the option to receive push notifications while using our Services. In order to serve push notifications, we may need to collect your IP address and a persistent identifier from your device. You can turn off push notifications in your device settings.
Personal Data and Non-Personal Data are collectively referenced as “Data.”
You may choose to allow us to access your location by granting the Site access to your location when prompted or through your device’s location services settings. You may change these settings on your device.
If you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Site, we may receive your Personal Data and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts through those services. For example, some social networking services allow you to push content from our Site to your contacts or to pull information about your contacts so you can connect with them on or through our Site. Some social networking services also will facilitate registration or enhance or personalize your experience on our Site. Your decision to use a social networking service in connection with our Site is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available by reviewing privacy policies of those providers and/or modifying your privacy settings directly with those networking sites/services.
For Legitimate Interests.
We use Non-Personal Data collected by clickstream information collection, web pixels, and cookies to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the our content and the products, services, materials, and other content that we describe or make available through the Site, and otherwise help administer and improve the Site.
We may identify you from your Personal Data [and merge or co-mingle Personal Data and Non-Personal Data]. Except as otherwise stated, we may use Information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to:
Consent. If you are a user accessing our Services from within the EEA and we have collected your Personal Data (such user herein referred to as a “Data Subject”) and we have obtained your consent, we may also use your Data in the following ways; and, if you are a citizen of any other jurisdiction, you acknowledge that we may use your information in the following ways:
In addition, we may use third‐party e‐mail providers to deliver communications to you. This is an opt-in e-mail program. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “unsubscribe” link or by contacting us.
[We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and Services. The information collected by these surveys is used to research market trends, company growth, community needs, etc. Your input will help us to improve customer experience and shape development of our products and Services].
We may share Personal Data [or Information] with the following parties:
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Data only for the purpose of performing services on our behalf. We have entered into contractual relationships with these service providers and require them to comply with all applicable information privacy laws and regulations and to use the Information only for the purposes for which it was disclosed. We require that any third-party service providers limit their use of your Information solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Information and not make unauthorized use or disclosure of the Information.
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment and (VI) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence;
- Pursuant to your express consent
We take reasonable steps online and offline to safeguard the Personal Data that you provide to us.
If you have any questions about security on our Services, or if you become aware of any unauthorized use of an account, loss of your account credentials, or suspect a security breach, notify us immediately via email at email@example.com. If our security system is breached, we will notify you of the breach to the extent required under applicable law.
[You may change, edit, update, or delete the information that you provided when you set up your account through our Service(s) through your account settings. You may also request the deletion of this information by sending an e-mail to firstname.lastname@example.org.] If you access our Services from certain jurisdictions, such as the EEA, you may have additional rights and options with regard to accessing, reviewing, correcting, and updating your Personal Data, as well as how we use and disclose your Personal Data.
As a Data Subject, you have the right to request access to your Personal Data as it exists in our records by [logging into the account you have created for yourself in Services account / e-mailing us at email@example.com]. You also have the right to rectification, correction, or amendment of your Personal Data if it is inaccurate or incomplete. You may also have the right to erasure of your Personal Data; however, this is not always possible due to legal requirements and exceptions may apply.
A Data Subject may have the right to object to the processing of his or her Personal Data, for example, due to his or her particular situation, for direct marketing uses, or for scientific or historical research. In certain circumstances, Data Subjects may have the right to obtain a restriction on our processing of their Personal Data, in which case such Personal Data will, with the exception of storage, only be processed with the Data Subject’s consent or in circumstances such as our exercise or defense of legal claims or the protection of another person. Data Subjects may also have the right to request that we provide data portability for their Personal Data via a copy of the data in a commonly-used format and/or transfer their Personal Data directly to another data controller (where technically feasible). Exceptions to these rights may apply, for example, if the processing is necessary for a task carried out in the public interest. Finally, if a Data Subject has given his or her consent to our processing of his or her Personal Data for certain purposes, he or she has the right to withdraw consent to such use at any time by contacting us via the contact information below.
If you are not satisfied with how we manage your Personal Data, you have the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here.
In some instances we may need to transfer your Personal Data outside the EEA. In all cases, we take steps to ensure that transfers of such Personal Data are performed in accordance with applicable law and carefully managed to protect your privacy rights and interests. Transfers are limited to countries that are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. Therefore, where we transfer your Personal Data outside our corporate affiliates or to third parties who help provide our products and services, we obtain contractual commitments to protect your Personal Data under Data Protection Agreements and pursuant to Standard Contractual Clauses. Some of these assurances are well recognized certification schemes or such as the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States. Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before disclosing any Personal Data.
We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Data from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to firstname.lastname@example.org.
By e-mail: email@example.com
By telephone: 1-800-775-0996