("COMPANY" OR "WE") SERVICES, INCLUDING WITHOUT LIMITATION
ANY OF ITS APPLICATIONS OR WEBSITES (THE "SERVICES") YOU CONSENT TO
DATA (AS DEFINED UNDER REGULATION (EU) 2016/679 (GENERAL DATA PROTECTION
REGULATION) ("PII") THAT YOU SUBMIT OR THAT IS PROCESSED OR COLLECTED
THROUGH THE SERVICES MAY BE PROCESSED BY THE COMPANY IN THE MANNER AND FOR THE
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES.
Information You Provide. If you use the Services (defined below), we will need your PII (defined below) such as your name, photo, address, e-mail address, phone number and your social network or third party service provider user ID through which you registered/accessed the Services
Information We Collect. We may collect your PII from third parties (including without limitation, from social media plug-in in the Services or from Third Party Platforms (defined below) you interact with or access the Services from), communications you send us, and aggregate data. We also automatically collect and record PII through your use of the Services such as your IP address, IDFA identifiers, cookie information, device ID and technical information regarding the method and nature of your use of the Services. At any time, you may opt-out from receiving newsletters and promotional communications from us.
How We Use Your Information. We use your PII for purposes such as providing you with, improving and operating the Services, understanding usage trends and user preferences, assisting users with online purchasing decisions, personalising the Services and interest based ads and in order to protect the Services from threatening activities.
Links. The Services may contain links to other services, sites and applications that are subject to their own privacy and data protection policies.
Children. We do not intend to collect PII from anyone we know to be under 13 years old. If you believe that we might have collected such information, please contact us.
Information Sharing. We grant access to your PII to our affiliates, representatives, agents, third party service providers and business affiliates on whose website or platform you use the Services. In addition, we may share your PII if required for the provision and maintenance and improvement of the Services; to satisfy applicable law; to prevent fraud or harm; to enforce agreements; or in the event of a merger, acquisition or other structural change or form of sale of part or all of our assets.
Information Security. We follow generally accepted industry standards to protect against unauthorised access, alteration, disclosure or destruction of your PII however we cannot guarantee its absolute security.
Retention Periods. We retain your PII as needed for the purposes for which it was collected and for lawful, ethical and document retention purposes.
Data Integrity. We process PII only for the purposes for which it was collected and take reasonable steps to ensure that the PII we process is accurate, complete and current. However, we depend on you to rectify your PII when necessary. We may delete or avoid from recording and storing any information at our discretion.
Data Subjects' Rights. At any time, you may contact us and request to exercise your rights in accordance with applicable law. For more details see Section 9 below.
Enforcement. We will cooperate with the appropriate regulatory authorities to resolve any formal written complaints regarding processing of PII that cannot be resolved between us and the complaining individual.
Consent to Processing and Transferring of PII. Your PII may be stored and processed in a country outside the country of your residence or from which you access the Services. Transfers of your PII outside the EEA will comply with applicable laws.
Your California Privacy Rights and Do Not Track Notices. If you are a California resident you may contact us and request information regarding your PII disclosed to third parties for their direct marketing purposes. We do not respond to Do Not Track signals.
1. Information We Collect and How We Use It. In order to provide and improve our Services, we may collect PII, including the following types of information:
1. Information You Provide. For some features of the Services we ask you for personal information, including: name, photo, email address, physical address, phone number, your social network or third party service provider user ID through which you accessed or registered to the Services (e. g. Facebook ID, hereinafter, "Third Party Platforms").
2. Third Parties. We sometimes supplement the information that you provide with information that is received from third parties. If you access the Services through any Third Party Platforms, or interact with any Third Party Platforms or other social media plug-in in the Services (such as a Facebook "Like" button) we may receive information from your respective social media or Third Party Platforms account, including your account information, photo and any information defined as public pursuant to the policies of such Third Party Platforms and/your settings in the respective Third Party Platform.
3. User Communications. When you send email or other communication to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may send you push notifications to send you news and updates in respect of the Services. We may also send you newsletters and promotional communications, you may opt-out of this service at any time by submitting a request at the following email address: email@example.com
4. Aggregated Personal Data. In an ongoing effort to better understand and serve the users of the Services, Company often conducts research on its customer demographics, interests and behaviour based on the PII and other information provided to us. This research may be compiled and analysed on an aggregate basis, and Company may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Company may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
5. User Information. When you use our Services, we may automatically receive and record information from your device and browser, including your IP address, IDFA identifiers (for iOS devices), Identifier for Advertising (for iOS devices) and Google Advertiser IDs (for Android devices) (such identifiers are collected herein for the following purposes, among other things: frequency capping, attribution, conversion events, estimating the number of unique users, advertising fraud detection, and debugging) cookie information, search history, device ID, Android ID, your regional and language settings, the physical location of your device (if you have permitted your mobile or other location-aware device to transmit location data), network status (WiFi/3G), and software and hardware attributes. We may use your location (city) (if you have permitted your mobile or other location-aware device to transmit location data) to learn how to adjust and personalise your use of the Services. Our systems may automatically record and store technical information regarding the method and nature of your use of the Services, including without limitation which pages of the Services our visitors view and impressions. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. The Company uses all of the PII that we collect to understand the usage trends and preferences of our users. We also use aggregate data for monetization.
6. The Company uses all of the PII that we collect for various reasons for example: We need the PII in order to provide or operate the Services, including to provide customer support and process your requests, questions and concerns; to understand the usage trends and preferences of our users; assist our users with online purchasing decisions; using information to personalise content and features on our sites and the services; collecting our services usage, analytics and performance data relating to our services, in order to maintain, analyse, develop, update, and improve our products and services; protecting against activities that may threaten the security, integrity, or availability of our or another party’s products, systems, and services; for personalising interest based ads; marketing and selling our products and services; maintaining corporate or business records consistent with our retention policies and applicable law. We also use aggregated data for monetization.
2. Cookies; web beacons and third party processors. In order to collect the data described herein we may use temporary cookies that remain on your device for a limited period of time. We may also use persistent cookies that remain on your device until manually removed in the settings of your device/browser, in order to manage and maintain the services and record your use of the Services. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your device. Cookies do not damage your device.
Some of the cookies that we set when you visit our Services are essential to the working functionality of the Services. Performance cookies are another type of cookies uses to provide with you a better user experience and to improve how content on our website is presented.
Most browsers or devices may allow you to block cookies block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not). We may also use web beacons via the Services to collect information. Web beacons or "gifs", are electronic images that may be used in our Services or in our emails. We use Web beacons to deliver cookies, count visits and to tell if and when an email has been opened and acted upon.
We also use third party tracking technologies (including technologies of Rakuten Marketing LLC, Amazon Services LLC and eBay Partner Networks Inc.'s), such as cookies and web beacons and various third party providers to process and analyze your PII, profile end user activities and provide targeted ads, including without limitation tracking your use of the Services and third party services and sites. To learn more about interest based ads and for certain opt-out options
Company is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to www.amazon.com.
3. Links. Links to other services, sites and applications may be provided by the Company as a convenience to our users. The Company is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This privacy statement applies solely to PII collected by us.
4. Children. If you are a child under the age of 13, you must obtain parental consent prior to using our Services. The Company will not knowingly contact or engage with children under the age of 13 without said parental consent. If you have reason to believe that a child has provided us with their PII, please contact us at the email address firstname.lastname@example.org and we will endeavour to delete that PII from our databases.
6. Information Security. We follow generally accepted industry standards to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.
7. Retention periods. We keep your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements, and delete any PII that is no longer useful or relevant to our operations.
8. Data Integrity. The Company processes PII only for the purposes for which it was collected and in accordance with this policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.
9. Data Subjects' Rights
Right of Access and Rectification. You have the right to know what PII we collect about you and to ensure that such data is accurate and relevant for the purposes for which Company collected it. We allow our users the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete or updated. However we may first ask you to provide us certain credentials to permit us to identify your PII.
Right to Delete Personal Information or Restrict Processing. You have the right to delete your PII or restrict its processing. We may postpone or deny your request if your PII is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.
Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your PII. Exercising this right will not affect the lawfulness of processing your PII based on your consent before its withdrawal.
You may exercise the above rights by sending a request to email@example.com
Right to Lodge Complaint. You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your PII.
Right of Data Portability. Where technically feasible, you have the right to ask to transfer your PII in accordance with your right to data portability
10. Enforcement. The Company regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or our treatment of PII by contacting our data protection officer at firstname.lastname@example.org. When we receive formal written complaints it is the Company's policy to contact the complaining user regarding his or her concerns. The user may also lodge complaint with relevant data protection authorities ,We will cooperate with the appropriate regulatory authorities in accordance with applicable law, including local data protection authorities, to resolve any complaints regarding the processing of PII that cannot be resolved between the Company and an individual.
We will notify you about significant changes in the way we treat PII by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Services. We encourage you to periodically review this policy for the latest information about our privacy practices.
12. Consent To Processing and Transferring of PII. By providing any PII to us pursuant to this policy, all users, including, without limitation, users in the United States, Israel ,member states of the European Union, and other regions, fully understand and unambiguously consent to this policy and to the collection and processing of such PII abroad. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the Services and may be outside your country of residence. Some of the uses and disclosures mentioned in this policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country. By submitting your PII through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this policy. If you do not consent to the terms of this policy, please do not use the Services. If we transfer your PII outside of the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient): https://www.privacyshield.gov/welcome, or enter into appropriate EC approved standard contractual clauses (see https://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm)
13. Questions. If you have any questions about this policy or concerns about the way we process your PII, please contact our Data Protection Officer at email@example.com
14. Your California Privacy Rights and Do Not Track Notices. California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of PII to third parties for their direct marketing purposes. To make such a request, please contact us using the contact details published on our Services. Please note that we are only required to respond to one request per customer each year. You are also advised that Company does not respond to “Do Not Track” signals.