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XXX (hereinafter “we”, “us” or “our”) operates the website XXX (hereinafter the “Website”) and is the controller of the information collected or provided via this Website.
If you have any questions about our privacy practices, please see “Contact Information” below for information on how to contact us.
- on this Website,
- in e-mail, text and other communications between you and this Website,
- through mobile applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website, or
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified by (“Personal Information”). It does not include data that has been anonymized or pseudonymized.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Persons who visit the Website without logging in or registering “unregistered users”:
- Technical Data includes internet protocol (IP) address, which we pseudonymize (a technique that replaces or removes information in the dataset that identifies an individual), browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website.
- User Submitted Data includes data collected at your direction for a specific function, for example a contest or survey.
- Usage Data includes aggregated information about how you use our Website, products and services.
- Persons who choose to create an account “registered users”
- Identity Data includes, username or similar identifier, date of birth and gender.
- Contact Data includes email address.
- Financial Data in case of purchases includes payment card details.
- Transaction Data in case of purchases, may include details about payments to and from you and other details of products and services you have purchased or received from us.
- Technical Data includes pseudonymized internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website.
- User Submitted Data includes data collected at your direction for a specific function, for example your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share your data to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature, to generate statistics about our users, to calculate the percentage of users accessing a specific Website feature, or to publish visitor demographics.
We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data). However, particular preferences and sexual orientation depend on how you use our Website and services. The processing of such Sensitive Personal Information may be necessary to provide some of our service to you.
HOW YOUR PERSONAL INFORMATION IS COLLECTED
We use different methods to collect data from and about you including through:
- Direct interactions. Information that you provide when carrying out search queries on our Website or by filling in forms on our Website, in particular at the time of registering to use our Website, subscribing to our service, posting material, taking part in surveys, entering a contest or promotion sponsored by us, when reporting a problem with our Website, or requesting further services.
INFORMATION COLLECTED THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information, search terms, and cookie information.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). Cookies are small text files that are stored in your web browser or downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie, and allow a website to recognize a user’s device.
We currently use the following types of cookies:
- Cookies that are strictly necessary: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.
- Analytical cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Website. These cookies help us to improve our Website, for example by ensuring that all users are able to find what they are looking for easily.
- Functionality cookies: These cookies are not essential, but help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.
- Targeting cookies: These cookies record the visit of a user on our Website, the pages a user has visited and the links a user has followed in order to enable us to make our Website more relevant to the users’ interests.
- Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, single-pixel gifs and web bugs) that are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted content from many providers, see “Choices About How We Collect, Use and Disclose Your Personal Information”.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the applicable local law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For purposes of providing the services, customer management and functionality and security as is necessary to perform the services provided to you under our term and conditions and any other contract that you have with us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where you declare your valid consent to use it.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
In general, we use information that we collect about you or that you provide to us, including Personal Information and Sensitive Personal Information, for following purposes:
- Provision of services (Registered Members Only): to present our Website and its contents to you, including any interactive features on our Website, and to provide you with information, products or services that you request from us; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with contests and sweepstakes;
- Customer management (Registered Members Only): to manage a registered users’ account, to provide customer support and notices to the registered user about his account, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through it;
- Customization of content (Registered Members Only): to perform research and analysis about your use of, or interest in, our Website content, products, or services, in order to develop and display content tailored to your interests on our Website and other sites;
- Analytics: to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns;
- Functionality and security: to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
- Compliance: to enforce our terms and conditions and to comply with our legal obligations;
DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not disclose your Personal Information except in the limited circumstances described here.
- We may disclose your Personal Information to members of our company group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, analytics, verifications, functionality and security, and compliance.
- Service providers. To our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, customization of content, analytics, security, supporting our Website functionality, surveys and other features offered through our Website. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes.
We access, preserve and share your Personal Information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to:
- satisfy any applicable law, regulation, legal process, or governmental request,
- detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues,
- protect against harm to the rights, property or safety of our company, our users, our employees, or others; or
- to maintain and protect the security and integrity of our Website or infrastructure.
In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.
Financial information (including Personal Information) that you have provided to us will only be shared with our third party processors in order to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and Personal Information for that purpose. All financial data and related Personal Information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party. All such information provided to a third party is subject to their terms and conditions.
TRANSFERS OF YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
By using the Website you consent to the transfer of information that we collect about you, including personal information, to any country in which we, members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) or our service providers are located.
RETENTION OF PERSONAL INFORMATION
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where permissible, we will also delete your Personal Data upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”.
If you have questions about our data retention practices, please send us an e-mail at XXX.
The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.
HOW WE PROTECT THE SECURITY OF YOUR PERSONAL INFORMATION
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.
You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
CHOICES ABOUT HOW WE COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us:
- You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of our Website because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Website.
- You may opt out of the DoubleClick cookie or of Google Analytics by visiting the Google advertising opt-out page or by downloading and installing the browser plug-in available at Google Analytics opt-out page.
- When you register on our Website. If you no longer want to receive commercial or promotional emails or newsletters from us, you will need to avail yourself of the unsubscribe mechanism set out in the applicable communication. It may take up to seven days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change you preferences directly with that third party.
- If you submit Personal Information, you may delete and deactivate your account with us at any time. If you deactivate and delete the information of your account, your Personal Information and any and all other account related information including, but not limited to, user profile data, sharing data and any other data, or content specifically associated with your account will no longer be accessible by you. After deleting and deactivating your account, if you choose to have an account with us in the future, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
YOUR RIGHTS RELATED TO YOUR PERSONAL INFORMATION
Subject to local law, you have certain rights regarding the Personal Information we collect, use or disclose and that is related to you, including the right:
- to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
- to rectify inaccurate Personal Information concerning you (right to data rectification);
- to delete/erase your Personal Information (right to erasure/deletion, “right to be forgotten”);
- to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability)
- to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object); and
- in some cases, to restrict our use of your Personal Information (right to restriction of processing).
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer able to use several functionalities of our Website and our services.
You may, at any time, send us an e-mail at XXX to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
CALIFORNIA CONSUMER PRIVACY ACT NOTICE
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:
- Opt-out of the sale of their personal information, should we sell their personal information;
- Be informed of certain information concerning our collection and use of their personal information;
- Request that we delete certain personal information we collected from them;
- Appoint an agent to exercise their rights provided for by the CCPA, provided that a duly executed notarized power of attorney is presented and provided that the agent has information deemed sufficient to allow us to verify the identity of the Consumer in question and to locate his/her information in our systems;
- Not be subjected to discrimination for the exercise of these rights. We will not deny California residents the use of our service, neither will we provide a different level or quality or services for exercising any of their CCPA rights, unless as permitted under the CCPA.
This Website does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information.
If the CCPA is applicable to you and you would like to exercise your rights, please contact XXX.
NO RIGHTS OF THIRD PARTIES
OUR POLICY TOWARDS MINORS
Our Website is not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect Personal Information from minors. If you become aware that your child has provided us with Personal Information, please contact us at XXX. If we become aware that a minor has provided us with Personal Information, we take steps to remove such information and terminate that person’s account.
NO ERROR FREE PERFORMANCE
GDPR (GENERAL DATA PROTECTION REGULATION)
In accordance with the General Data Protection Regulation law in the European Union effective May 25, 2018, XXX users can request a copy of their personal data as well as get XXX to delete their personal data.
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