Last Modified: May/24/2018
For the purposes of EU data protection laws (“Data Protection Law”), Company is data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
3. SHARING OF YOUR INFORMATION
4. THIRD PARTY TRACKING AND ONLINE ADVERTISING
5. CONTROL OVER YOUR INFORMATION
6. HOW WE STORE AND PROTECT YOUR INFORMATION
7. CHILDREN’S PRIVACY
8. LINKS TO OTHER WEB SITES AND SERVICES
9. HOW TO CONTACT US
1. WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?
The categories of information we collect can include personal information, such as your name, phone number, and e-mail address when you communicate with us. We may also collect any communications between you and Company and any other information you provide to Company and its representatives. We use this information to operate, maintain, and provide to you the features and functionality of the Site, as well as to communicate directly with you, including to send you email messages and phone calls.
2. LEGAL BASIS FOR PROCESSING IN THE EU
In the EU, the purposes for which we process your personal data are:
1. where we need to perform a contract we are about to enter into or have entered into with you;
2. 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 such as to provide our services to you, to provide you with the Site, to contact you and respond to your requests and enquiries, for fraud prevention and detection; and
3. Where we need to comply with a legal or regulatory obligation in the EU.
We, and our third party partners, automatically collect certain types of usage information when you visit our Site or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies 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 Site, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Site, whether you open emails or click the links contained in emails and other actions you take on the Site. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users.
4. SHARING OF YOUR INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below. We may share your personal information with:
• Third parties at your request.
• Other companies and brands owned or controlled by Company, and other companies owned by or under common ownership as Company. These companies will use your personal information in the same way as we can under this Policy;
• 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;
• Third-party vendors and other service providers that perform services on our behalf;
• Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
• We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
5. 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 website over time so that they may play or display ads that may be relevant to your interests on our Site 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 Site 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 optout of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources and/or the DAA’s resources, 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 and downloading the mobile AppChoices app. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices. 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.
Facebook Custom Audience Ads
We may work with Facebook to display interest-based ads to you or to your friends on Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalize our ads based on you or your friends’ experience on our Site in order to provide ads tailored for each specific recipient. We do not share personal information about your activities on our Site with Facebook, but we share a hashed email address or phone number which permits Facebook to identify our advertising audience based on the information that Facebook collects from its users. If you do not want to receive interest-based ads on Facebook, you can adjust your ad preferences through your Facebook settings. If you do not want us to use your content to personalize advertising that we direct to your friends on Facebook, you may email us at firstname.lastname@example.org.
6. CONTROL OVER YOUR INFORMATION
How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications, or by contacting us directly at the email address below. We make every effort to promptly process all unsubscribe requests. Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
7. HOW WE STORE AND PROTECT YOUR INFORMATION
Keeping your information safe: We care about the security of your information and use commercially reasonable safeguards to preserve the integrity and security of all information collected through our website. 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 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 “WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?“), except if required otherwise by law.
7. CHILDREN’S PRIVACY
Company does not knowingly collect or solicit any information from anyone under the age of 13 on this Site. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
8. 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:
a. Right of access. The right to obtain access to your personal data.
b. Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
c. 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.
d. 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.
e. Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
9. LINKS TO OTHER WEB SITES AND SERVICES
The Site may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.
10. HOW TO CONTACT US