Collection of information
We may collect personal information (including Personal Data) and other information about you, including but not limited to the following:
- Registration Information: When you register for a Service, you will be asked for basic registration information, such as an email address and password.
- Third-Party Authorization: You may also enter in certain account information for third-party sites and Internet services (“Third-Party Sites”).
- Information from Third-Party Sites: In order to display information to you or to fulfill your requests for certain products and services through a Service, we may collect, on your behalf, your account and other personal information from Third Party Sites that you register under your account via the Service. We may also collect information about you from mailing list providers, publicly available sources, and other third parties, including to process and manage your application and transactions.
- Technical and Navigational Information: We may collect your computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our web design and functionality.
- Device ID: When you use the mobile versions of our Site, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (“Device ID”). Device IDs allow app developers, and others to uniquely identify your device for purposes of storing application preferences and other data.
We take reasonable steps designed to ensure that your Personal Data that we process are limited to the Personal Data reasonably required in connection with the purposes set out in this Policy. We do not seek to collect or process Personal Data about race, ethnicity, national origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, or sexual life. Nor do we collect any information about criminal convictions and offenses. Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide our client with Services). In this case, we may have to cancel a product or service but we will notify you if this is the case at the time.
Use of your information
We may use, save and analyze the information you provide about yourself and about your Third-Party Sites (together “Data Processing”). Such Data Processing is necessary to perform our Services to you, including:
- to fulfill your requests for our products, programs and Services,
- to respond to your inquiries about our Services and verify your identity,
- to provide customer support,
- to offer you other products, programs, or services that we believe may be of interest to you,
- to verify the existence and condition of your accounts and conduct due diligence,
- to fulfill legal requirements,
- to protect against potentially prohibited or illegal activities,
- to improve (including through data analytics), monitor and personalize the Services and conduct our business and to provide targeted marketing and advertising,
- to measure the performance of and improve the Site or mobile application functionality, and
- to manage, administer and protect our information technology infrastructure and Site security generally.
If information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose.
We will not reuse your Personal Data for a new purpose other than the original one(s) for which it was collected, unless one or more of the following apply:
- the new use is compatible with the original use such that you would reasonably expect such a similar use;
- we have notified you of the new use and given you an opportunity to authorize it; or
- the new use is otherwise permitted or required by law.
In an ongoing effort to better understand and serve the users of the Services and improve data analytics, research and analysis may be compiled and analyzed on an anonymized basis, and we may share this anonymized data with its affiliates, agents and business or financing partners. This aggregate information does not identify you personally.
Sharing of information
We may share personal information about you as follows and you hereby consent to such sharing:
- With our service providers, agents, consultants and related third parties to perform certain business-related functions such as offering customer service, processing diligence or secure data storage, in each case only as necessary to provide these types of services to us;
- With third parties to provide, maintain, and improve our Services;
- To respond to a request of a governmental entity, subpoenas, court orders, or legal process;
- To respond to claims that any posting or other content violates the rights of third parties;
- If required to do so by law or in the good faith belief that such action is necessary to:
- comply with any legal obligation;
- generally protect against legal liability or otherwise protect our rights; or
- to protect the health and safety of our Sites’ users or the general public in an emergency; or
- To any other third party with your consent.
We may display personal testimonials of customers on our Site. We may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us by email at email@example.com.
Your rights and data retention
You have the right to ask us not to process your personal information for marketing purposes. You can do this at any time by updating your email preferences in your account or by clicking on the “unsubscribe” link in any marketing email we send you. You can also opt out of marketing by emailing firstname.lastname@example.org.
Data protection law may give you the right to access your personal information, to object to the use of your personal information for certain purposes, and the right to erase or restrict your personal information. Further, you may request the transfer of your personal data to you, or (if technically feasible) to a third party in a machine-readable format. Note that these rights only apply to personal data which you initially provided us. You can make any such requests by emailing email@example.com. Certain personal information will need to be retained for administrative, legal, security or other legitimate business purposes.
You can easily access personal information that you have submitted to us and request the correction of any inaccurate information you have submitted to us, via your user account. Alternatively, you can send an email that includes your contact information to firstname.lastname@example.org to request any corrections, or access, to your personal information.
We will handle your requests and rights in accordance with the law. This means there may be legal reasons why we cannot fulfil all requests. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one week. Occasionally it may take us longer than a week if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You may have the right to lodge complaints with a data protection authority regarding the processing of your Personal Data.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, administrative, security, compliance, accounting, or reporting requirements. We will need to retain your information for as long as your account is active. We will retain and use your information as necessary to comply with (and demonstrate compliance with) our legal obligations, resolve disputes, collect on amounts owing and enforce our agreements. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We take reasonable measures, including firewall barriers, SSL encryption techniques, and authentication procedures, to help protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to us via the Internet. If you have any questions regarding the security of your personal information, you can contact us by email at email@example.com.
We may provide our registered customers with summaries of their account information and email alerts. We may also allow users to subscribe to email newsletters and from time to time may transmit emails promoting us or third-party goods or services. You have the ability to opt out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails or by contacting us by email at firstname.lastname@example.org. Opting out in this manner will not end transmission of service-related emails, such as email alerts.
Certain privacy laws around the world, including the European General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), provide users with rights related to their personal information. Consistent with those laws, we give you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Site, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
- Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.
- Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
- Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of the Site.
- Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
- Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
The CCPA provides California residents with the following additional rights:
- Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
- Right to Opt-Out: To the extent that we “sell” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).
If you would like to manage, change, limit, or delete your personal information, you can contact us by email at email@example.com.
Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. If you need further assistance, you can contact us by email at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification, and we may verify the authenticity of the request directly with you.
The CCPA requires disclosure of the categories of personal information collected over the past 12 months. The categories of personal information that we have collected – as described by the CCPA – are:
- Identifiers, including name, physical address email address,
- Other individual records such as phone number, billing address, or credit or debit card information. This category includes personal information protected under pre-existing California law (Cal. Civ. Code § 1798.80(e)), and overlaps with other categories listed here.
- Demographics, such as your age or gender.
- Commercial information, including purchases and engagement with the Services.
- Internet activity, including your interactions with our Services and what led you to our Services.
- Geolocation data provided through location enabled services such as WiFi and GPS.
- Inferences, including information about your interests, preferences and favorites.
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. We do not share any personal information to third parties for their own direct marketing purposes.