Last Modified: February 22, 2023
In the course of your use of the Services, we will obtain the information about you described below. We may need to collect this information to provide you with services or information you request, or to facilitate commercial engagements with you. If you do not provide such information, we may not be able to provide the Services to you, or enter commercial engagements with you. We will only collect information about you that is necessary for one or more legitimate business purposes, or that is required by law. We collect the following information:
● Information you provide as part of the registration process, such as your email, name, and country when you provide it to us
● Information that you provide when you call or email us (for support or otherwise) or when you use our products or services
· If you make any payments through the Services, we will collect any information provided in connection with such payment, including name, address, email address, mobile number, and credit card number or other payment information
● Data relating to your online activity on the Site or App, including the following:
o IP address (on an anonymized basis)
o browser type and version
o geographic location
o pages you view and features you use on the Site or App
o how you got to the Site or App and any links you click on to leave the Site or App
o when you update your information or communicate with Us
o metadata about your use of the Site or App and the communication that you send in-site or in-app
o your interactions with any features and other Content we offer
o issues you encounter requiring our support or assistance
o any device or other method of communication you use to interact with the Site or App
● We use various technologies to collect and store information when you use the Site or App. We may store the data we collect in a variety of places within our infrastructure, including system log files, back-end databases and analytics systems. We do not provide an option to do-not-track request via web browser
● While using the Services, you may provide Feedback to us. We will collect any information you provide as part of this Feedback and use it to improve the Services for you and other users n anonymized form
● Information that is publicly available
● Information you consent to us receiving from third parties
HOW WE USE YOUR INFORMATION
We do not sell your data or private information to others. We use the information we collect about you to:
● Provide you with access to the Services;
● Ensure the proper functioning of our services and diagnose problems with our servers, the App, or the Site;
● Provide you with requested information or technical support;
● Provide you with advertising information and materials. If we send you any marketing emails, you may unsubscribe from them by following the link embedded in the email;
● Process payments;
● Operate security and compliance programs, including investigating any violation of the Terms or applicable law;
● Gather aggregated, anonymized, statistical data about how the Site and App are being used to analyze usage trends and improve the Site and App and the advertising content on it. We may share this anonymized data with third parties; and
● Assist us in offering you a personalized experience or otherwise tailor the Services to you.
We do not use your personal data for the purposes of automated decision-making or profiling. If we do so in the future, we will inform you of any such processing and provide you with an opportunity to object.
SHARING OF INFORMATION
We will only share certain personal information as further described below.
Sharing with Third Party Service Providers and Vendors
Occasionally, we enter into contracts with carefully selected third parties so that they can assist in servicing you or to assist us in our own marketing and advertising activities (including providing us with analytic information and search engine optimization services). Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.
We also share aggregated, anonymized, statistical information on how the Site and App are being used with certain third parties, including the media, industry observers, marketing and advertising partners, vendors, customers, potential customers or partners.
If we are involved in a merger, acquisition, a sale of all or a substantial portion of its assets, or other similar sale transaction, your information may be transferred as part of that transaction. We will notify you by email and/or a prominent notice on the Site and App of any such transfer and any choices you may have regarding your information.
All users authorized by you to have access to your Account can view personal information stored in the Account.
Lastly, if legally required to do so, or if we have a good faith belief that such disclosure is reasonably necessary, we may disclose your personal information to courts of law, law enforcement authorities and other relevant third parties, such as internet service providers, to conduct an investigation, respond to a third party or law enforcement subpoena or court order, bring legal action, prevent harm to others or pursue other relief when you or a third party are or may be:
● violating the Terms;
● causing injury or other harm to, or otherwise violating the property or other legal rights, of us, other users of the Site or App, or third parties; or
● violating federal, state, local, or other applicable law.
This disclosure can include transferring Your information to the U.S. and other countries outside the European Economic Area. We will notify you if we are required to provide your personal information to third parties in connection with a subpoena.
The transmission of information via the internet, email or text message is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted through or in connection with the Services or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.
You can always opt out of our marketing communications or change your preferences by following a link in the footer of all non-transactional, or otherwise essential, email messages from us or by emailing us at [ ]. Some communications from us are considered transactional or service communications (for example, important Account notifications and content reaction correspondence), and your Account is provided to you upon the condition that you receive these communications from us. You must cancel your Account if you do not wish to receive any transactional or service communications. To cancel your Account, please follow the instructions found in the Terms. You may still receive marketing communications from us even after you cancel your Account unless you also opt-out of our marketing communications, as described above.
We retain your personal information to provide Services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than one month following the date on which you terminate your use of the Services, unless we are otherwise required by law or regulation to retain your personal information for longer.
In certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We will respond to any requests regarding your personal information in accordance with the laws of your local jurisdiction. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the Account holder. For each of the rights below we may have valid legal reasons to refuse your request; in such instances we will let you know. Your local jurisdiction may provide you with the following rights:
You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
You have the right to require us to correct any personal information held about you that is inaccurate. Where you request correction, please explain in detail why you believe the personal information we hold about you is inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
You may request that we erase the personal information we hold about you in the following circumstances:
● where you believe it is no longer necessary for us to hold the personal information;
● we are processing it on the basis of your consent and you wish to withdraw your consent;
● we are processing your data on the basis of our legitimate interest and you object to such processing;
● you no longer wish us to use your data to send you marketing communications; or
● you believe we are unlawfully processing your data.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please send your request by e-mail to us at email@example.com.
If you reside in California and have provided Personal Data to Us, you have the right to receive: (a) information identifying any third party to whom we may have disclosed, within the past year, personal data pertaining to you and your family for that party’s direct marketing purposes; and (b) a description of the categories of personal data disclosed. To obtain such information, please email your request to firstname.lastname@example.org. This request may be made no more than once per calendar year.
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:
● You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
● We wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
● We no longer need the personal information for processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
● You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
Please send any objections to us by e-mail at email@example.com.
Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by e-mailing us at firstname.lastname@example.org.
Some parts of the Site or App may provide links to other sites. Because we do not control the information policies or practices of these third-party sites, you should review their privacy policies to learn about how they collect and use personal information.
Our Services are not directed to persons under 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 18 has provided us with personal information, we will delete such information from our files.
In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in the United States. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
For transfers of personal information within our corporate family, such transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.
For transfers of data to third parties, such transfers will either (i) be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework.
If you wish to make a complaint about how we process your personal information, please contact us at email@example.com and we will try to deal with your request.