Last modified: May 24, 2018
For the purposes of EU data protection laws (“EU Data Protection Law”), Company is a data controller (i.e., the Company is responsible for, and controls the processing of, your personal data).
For information about how we collect and use information about our customers’ end users, please see the section below headed “Customer Data”.
- How We Collect and Use Information
We collect your personal information in order to provide you with a personalized, useful and efficient experience. The categories of information we collect can include:
Information that you provide to us. We collect information that you provide to us when you set up an account with us, use our Service, or communicate with us. For example, we may request your personal information (e.g., name, postal address, email address, DOB, telephone number, credit/debit card number, security code) or your applicable business information when you register for an account or purchase our Service. We may also collect any communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Service (e.g., promotions, surveys, etc.). We collect information you may provide when providing content or commentary to our Service in the form of blog posts, comments, and the like, which may be published on our site and viewable by the public.
Information we receive from social networking sites. When you interact with our Service through various social media, such as when you login through Facebook, or share Company content on Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our websites or Service.
We use this information to operate, maintain, improve and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.
We, and our third party partners, automatically collect certain types of usage information when you visit our websites, read our emails, or otherwise engage with us or our Service. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our websites or Service, for example, the site from which you came and the site to which you are going when you leave our websites, the pages you visit, the links you click, how frequently you access the websites or Service, whether you open emails or click the links contained in emails, whether you access the websites or Service from multiple devices, and other actions you take on our websites or Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the websites, as some features and services on our websites may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as HTML5. If you choose to delete Local Storage Objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.
- How We Share Personal Information
We may share your personal information in the instances described below. For further information on your choices regarding your information, see “Control Over Your Information.”
- We may share your personal information with other users of the Service, and with third parties with whom you communicate or transact with on the Service.
- We may share your personal information with third parties at your request or with your consent.
- We may share your personal information with the public if you choose to create a “public profile” that will be available to others on the Internet. Please do not provide personal information you do not want to be public.
- We may share your personal information with third-party service providers or business partners who help us deliver or improve our service or who perform services on our behalf, such as identifying and serving targeted advertisements, processing payments, sending postal mail, providing back-office services, or measuring site traffic.
- We may share your personal information with third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the official rules of the contest or sweepstakes.
- We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms and Conditions.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
- Customer Data
In providing our Service, our customers may upload data to our Service, which may include personal information or data about our customers’ end users (all of which we call “Customer Data”). Customer Data is owned and controlled by our customers, and any Customer Data that we maintain or process we consider to be strictly confidential. We collect and process Customer Data solely on behalf of our customers, and in accordance with our agreements with the customers. We do not use or disclose Customer Data except as authorized and required by our customers and as provided for in our agreements with our customers.
- Legal Basis for Processing Your Information in the EU
In the EU, the purposes for which we process your personal data are:
- The provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
- Where it is necessary for compliance with our legal obligations laid down by EU law;
- Where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms – this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
- to contact you and respond to your requests and enquiries;
- for business administration, including statistical analysis;
- to provide the Service to you;
- for fraud prevention and detection; and
- to comply with applicable laws, regulations or codes of practices.
We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under the EU Data Protection Law to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.
- Control Over Your Information
Email Communications. From time to time, we may send you emails regarding updates to our websites, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Service-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the websites or Service. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below. Please note that Company does not own or control the Customer Data uploaded to our Service by our customers, and cannot modify or delete Customer Data except at the request of our customer, or as permitted by our .
- Third Party Tracking and Online Advertising
We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our websites over time so that they may play or display ads that may be relevant to your interests on our websites as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information. This information is used to display targeted ads on or through our websites or on other websites or apps, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at email@example.com.
- Data Protection and Security
Data Retention: Following termination or deactivation of your User account, Company may retain your information commercially reasonable time for record keeping, audit or other purposes. Any Customer Data that we have access to shall be retained, stored, and deleted according to our agreement with our business customer.
Data storage and transfer: For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under “How We Collect and Use Information”), except if required otherwise by law. Your information collected through the Service may be stored and processed in the United States or any other country in which the Company or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and such transfers are made pursuant to appropriate safeguards. For more information regarding Company’s compliance with the U.S.-EU and U.S.-Swiss Privacy Shield Principles, please see our Privacy Shield Statement.
Keeping information safe: Company cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
- For Residents in the EU and Switzerland
If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:
- Right of access. The right to obtain access to your personal data;
- Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete;
- Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed;
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data;
- Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another; and
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- Links to Third-Party Websites and Service
- Children’s Privacy
Company’s website and services are intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at firstname.lastname@example.org.
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