Last revised on August 25, 2020
Collection and Storage of Your Personal Information
We collect and use the following types of information about you:
Non-personal Information is non-identifiable information that, when taken alone, cannot be used to identify you. As such, we are not aware of the identity of the user from which the Non-personal Information was collected.
For the avoidance of doubt, if we combine Personal Information with Non-personal Information (e.g. analytics data), the combined information will be treated as Personal Information as long as it remains combined.
Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual. We gather the following types of Personal Information:
Name, email address, and other contact information: We ask for and — at your option—collect your contact data (such as name and email address) from you when you submit web forms on our Website, including filling out application forms to join our mailing list or contacting us for any other reason. We will send such communications in accordance with applicable law.
Voluntary information: We collect Personal Information that Users provide us voluntarily. For example, when they respond to communications from us, or when they share additional information through their use of the Website and Services.
Device information: We collect from our Users specific types of connection details and information with regard to their device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation.
How we Use Personal Information
In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:
Provide, operate, maintain, improve, and promote our Services;
Enable you to access and use our Services;
Send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;
Send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners (see more under “Marketing”);
To serve you advertisements that are relevant to you and your interests when you use our site (see more under “Advertising“)[HFN1]
monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes;
Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
Personalize the Services, including by providing features or content that match your interests and preferences; and[HFN2]
Process for other purposes for which we obtain your consent.
With whom do we share the Personal Information we collect?
Specifically, we do not permit our Service Providers to use any Personal Information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.
In addition to sharing with Service Providers as described above, we may also share your Personal Information with others in the following circumstances:
With other subsidiaries or affiliate companies;
In the event of a merger, sale, change in control, or reorganization of all our part of our business;
When we are required to disclose Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required to comply with our legal obligations; or
As you may otherwise consent from time to time.
Third-parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.
Why we use your Personal Information
Please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g. to deliver the service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.
In some cases, we may need the Personal Information to protect your vital interests or those of another person.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.
We may use your Personal Information, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Services.
At any time, you may request to unsubscribe and discontinue receiving marketing offers by sending us a blank message with the word “remove” to the contact details available below.
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you Services-related updates and notifications.
We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.[HFN5]
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. You may have the right to certain actions to your Personal Information such as:
To receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
To request rectification of your Personal Information that is in our control.
To request the erasure of your Personal Information.
To object to the processing of Personal Information by us.
To request to restrict the processing of your Personal Information by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.
For how long do we retain the Personal Information that we collect?
We retain the Personal Information that we collect from Users for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time. Under applicable regulations, we will keep records containing your Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
International Transfer (for Users for the EEA)
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA. In these instances, we will transfer your Personal Information only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
How do we safeguard your Personal Information?
We take great care in implementing and maintaining the security of the Services and your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Users’ data, safety of your Personal Information, and prevent unauthorized use of any such information.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information despite our efforts. You should note that by using our Services, your Personal Information will be transferred through third party infrastructures which are not under our control. 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 Personal Information, we cannot guarantee its absolute security.
We do not knowingly collect or solicit personal information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Websites or Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected personal information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.
Changes to the policy
How to contact us
If you have any questions about this policy, please contact our data privacy representative at email@example.com