This privacy
notice for [Company Name] (doing business as [Company Short Name]) ("we," "us,"
or "our"), describes how
and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
■
Visit our website
at [Website URL], or any website of ours that
links to this privacy notice
■
[Download
and use our application(s), such as our mobile application — [Mobile App Name],
[our Facebook application — [Facebook App Name],] or any other application of
ours that links to this privacy notice]
■
Engage with us in
other related ways ― including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please
do not use our Services. If you still have any questions or concerns, please
contact us at [Email Address].
This privacy
policy was created by Termly’s Privacy Policy Generator.
SUMMARY OF KEY POINTS
This summary
provides key points from our privacy notice, but you can find out more details
about any of these topics by clicking the link following each key point or by
using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal
information depending on how you interact with us and the Services, the choices
you make, and the products and features you use. Learn more about personal information you
disclose to us.
Do we process any sensitive personal information? [We do not process sensitive personal
information. / We may process sensitive personal information when necessary
with your consent or as otherwise permitted by applicable law. Learn more about
sensitive
information we process.]
Do we receive any information from third parties? We may receive information from public databases, marketing partners,
social media platforms, and other outside sources. Learn more about information collected from
other sources.
How do we process your information? We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to
comply with law. We may also process your information for other purposes with
your consent. We process your information only when we have a valid legal
reason to do so. Learn more about how we process your
information.
In what situations and with which types of parties
do we share personal information? We may
share information in specific situations and with specific categories of third
parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place
to protect your personal information. However, no electronic transmission over
the internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or
other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Learn more about
how
we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal
information. Learn more about your privacy rights.
How do I exercise my rights? The easiest way to exercise your rights is by filling out our data
subject access request form available here: [DSAR Form
URL], or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to
learn more about what we do does with any information we collect? Review the privacy notice in
full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
2. HOW DO WE PROCESS YOUR
INFORMATION?
3. WHAT LEGAL BASES DO WE
RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON
THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND
OTHER TRACKING TECHNOLOGIES?
7. HOW DO WE HANDLE YOUR
SOCIAL LOGINS?
8. IS YOUR INFORMATION
TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR
INFORMATION?
10. HOW DO WE KEEP YOUR
INFORMATION SAFE?
11. DO WE COLLECT INFORMATION
FROM MINORS?
12. WHAT ARE YOUR PRIVACY
RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK
FEATURES
14. DO UNITED STATES
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO
THIS NOTICE?
17. HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION
DO WE COLLECT?
Personal
information you disclose to us
In Short: We collect personal
information that you provide to us.
We collect
personal information that you voluntarily provide to us when you [register on the Services,] express an interest in
obtaining information about us or our products and Services, when you
participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of
your interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may include
the following:
■
[Personal
Info Collected]
■
[Personal
Info Collected]
■
[Personal
Info Collected]
Sensitive
Information. [We do not
process sensitive information. / When necessary, with your consent or as
otherwise permitted by applicable law, we process the following categories of
sensitive information:
■
[Sensitive
Info Collected]
■
[Sensitive
Info Collected]
■
[Sensitive
Info Collected]]
Payment Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number (such as a credit card
number), and the security code associated with your payment instrument. All
payment data is stored by [Vendor Name]. You
may find their privacy notice link(s) here: [Vendor
Privacy Policy].
Social Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, Twitter, or other
social media account. If you choose to register in this way, we will collect
the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL
LOGINS?" below.
[Application Data. If you use our application(s), we also may collect the
following information if you choose to provide us with access or permission:
■
Geolocation Information. We may request access or permission to track location-based
information from your mobile device, either continuously or while you are using
our mobile application(s), to provide certain location-based services. If you
wish to change our access or permissions, you may do so in your device's
settings.
■
Mobile Device Access. We may request access or permission to certain features
from your mobile device, including your mobile device's bluetooth, calendar,
camera, own, and other features. If you wish to change our access or
permissions, you may do so in your device's settings.
■
Mobile Device Data.
We automatically collect device information (such as your mobile device ID,
model, and manufacturer), operating system, version information and system
configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or
mobile carrier, and Internet Protocol (IP) address (or proxy server). If you
are using our application(s), we may also collect information about the phone
network associated with your mobile device, your mobile device’s operating
system or platform, the type of mobile device you use, your mobile device’s
unique device ID, and information about the features of our application(s) you
accessed.
■
Push Notifications.
We may request to send you push notifications regarding your account or certain
features of the application(s). If you wish to opt out from receiving these
types of communications, you may turn them off in your device's settings.
This
information is primarily needed to maintain the security and operation of our
application(s), for troubleshooting, and for our internal analytics and
reporting purposes.]
All personal
information that you provide to us must be true, complete, and accurate, and
you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information —
such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our Services.
We
automatically collect certain information when you visit, use, or navigate the
Services. This information does not reveal your specific identity (like your
name or contact information) but may include device and usage information, such
as your IP address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country, location,
information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and
operation of our Services, and for our internal analytics and reporting
purposes.
Like many
businesses, we also collect information through cookies and similar
technologies. You can find out more about this in our Cookie Notice: [Cookie Notice URL].
The
information we collect includes:
■
Log and Usage Data. Log and usage data
is service-related, diagnostic, usage, and performance information our servers
automatically collect when you access or use our Services and which we record
in log files. Depending on how you interact with us, this log data may include
your IP address, device information, browser type, and settings and information
about your activity in the Services (such as the date/time stamps associated
with your usage, pages and files viewed, searches, and other actions you take
such as which features you use), device event information (such as system
activity, error reports (sometimes called "crash dumps"), and
hardware settings).
■
Device Data. We collect device
data such as information about your computer, phone, tablet, or other device
you use to access the Services. Depending on the device used, this device data
may include information such as your IP address (or proxy server), device and
application identification numbers, location, browser type, hardware model,
Internet service provider and/or mobile carrier, operating system, and system
configuration information.
■
Location Data. We collect
location data such as information about your device's location, which can be
either precise or imprecise. How much information we collect depends on the
type and settings of the device you use to access the Services. For example, we
may use GPS and other technologies to collect geolocation data that tells us
your current location (based on your IP address). You can opt out of allowing
us to collect this information either by refusing access to the information or
by disabling your Location setting on your device. However, if you choose to
opt out, you may not be able to use certain aspects of the Services.
■
[Other]
Information
collected from other sources
In Short: We may collect limited
data from public databases, marketing partners, social media platforms, and
other outside sources.
In order to
enhance our ability to provide relevant marketing, offers, and services to you
and update our records, we may obtain information about you from other sources,
such as public databases, joint marketing partners, affiliate programs, data
providers, social media platforms, and from other third parties. This
information includes mailing addresses, job titles, email addresses, phone
numbers, intent data (or user behavior data), Internet Protocol (IP) addresses,
social media profiles, social media URLs, and custom profiles, for purposes of
targeted advertising and event promotion. If you interact with us on a social
media platform using your social media account (e.g., Facebook or Twitter), we
receive personal information about you such as your name, email address, and
gender. Any personal information that we collect from your social media account
depends on your social media account's privacy settings.
[Information collected when you use our
Facebook application(s). We by default access your Facebook basic account information, including your name, email,
gender, birthday, current city, and profile picture URL, as well as other
information that you choose to make public. We may also request access to other
permissions related to your account, such as friends, check-ins, and likes, and
you may choose to grant or deny us access to each individual permission. For
more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.]
2. HOW DO WE
PROCESS YOUR INFORMATION?
In Short: We process your
information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety
of reasons, depending on how you interact with our Services, including:
■
To facilitate account creation and authentication and otherwise manage
user accounts. We may process your information so you can
create and log in to your account, as well as keep your account in working
order.
■
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested
service.
■
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve
any potential issues you might have with the requested service.
■
To send administrative information to you. We may process your information to send you details about our products
and services, changes to our terms and policies, and other similar information.
■
To fulfill and manage your orders. We may process your information to fulfill and manage your orders,
payments, returns, and exchanges made through the Services.
■
To enable user-to-user communications. We may process your information if you choose to use any of our
offerings that allow for communication with another user.
■
To request feedback. We may process your
information when necessary to request feedback and to contact you about your
use of our Services.
■
To send you marketing and promotional communications. We may process the personal information you send to us for our
marketing purposes, if this is in accordance with your marketing preferences.
You can opt out of our marketing emails at any time. For more information, see
"WHAT
ARE YOUR PRIVACY RIGHTS?"
below).
■
To deliver targeted advertising to you. We may process your information to develop and display personalized
content and advertising tailored to your interests, location, and more. For
more information see our Cookie Notice: [Cookie Notice
URL].
■
To protect our Services. We may
process your information as part of our efforts to keep our Services safe and
secure, including fraud monitoring and prevention.
■
To identify usage trends. We may
process information about how you use our Services to better understand how
they are being used so we can improve them.
■
To determine the effectiveness of our marketing and promotional
campaigns. We may process your information to better
understand how to provide marketing and promotional campaigns that are most
relevant to you.
■
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an
individual’s vital interest, such as to prevent harm.
■
[Other]
3. WHAT LEGAL BASES
DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process
your personal information when we believe it is necessary and we have a valid
legal reason (i.e., legal basis) to do so under applicable law, like with your
consent, to comply with laws, to provide you with services to enter into or
fulfill our contractual obligations, to protect your rights, or to fulfill our
legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General
Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid
legal bases we rely on in order to process your personal information. As such,
we may rely on the following legal bases to process your personal information:
■
Consent. We may process your information if you have
given us permission (i.e., consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
■
Performance of a Contract. We may
process your personal information when we believe it is necessary to fulfill
our contractual obligations to you, including providing our Services or at your
request prior to entering into a contract with you.
■
Legitimate Interests. We may process
your information when we believe it is reasonably necessary to achieve our
legitimate business interests and those interests do not outweigh your
interests and fundamental rights and freedoms. For example, we may process your
personal information for some of the purposes described in order to:
■
Send users
information about special offers and discounts on our products and services
■
Develop and display
personalized and relevant advertising content for our users
■
Analyze how our
Services are used so we can improve them to engage and retain users
■
Support our
marketing activities
■
Diagnose problems
and/or prevent fraudulent activities
■
Understand how our
users use our products and services so we can improve user experience
■
[Other]
■
Legal Obligations. We may process
your information where we believe it is necessary for compliance with our legal
obligations, such as to cooperate with a law enforcement body or regulatory
agency, exercise or defend our legal rights, or disclose your information as
evidence in litigation in which we are involved.
■
Vital Interests. We may process
your information where we believe it is necessary to protect your vital
interests or the vital interests of a third party, such as situations involving
potential threats to the safety of any person.
In legal
terms, we are generally the “data controller” under European data protection
laws of the personal information described in this privacy notice, since we
determine the means and/or purposes of the data processing we perform. This
privacy notice does not apply to the personal information we process as a “data
processor” on behalf of our customers. In those situations, the customer that
we provide services to and with whom we have entered into a data processing agreement
is the “data controller” responsible for your personal information, and we
merely process your information on their behalf in accordance with your
instructions. If you want to know more about our customers' privacy practices,
you should read their privacy policies and direct any questions you have to
them.
If you are located in Canada, this section applies to you.
We may
process your information if you have given us specific permission (i.e.,
express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e., implied consent). You
can withdraw your consent at any time. Click here to learn more.
In some
exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
■
If collection is
clearly in the interests of an individual and consent cannot be obtained in a
timely way
■
For investigations
and fraud detection and prevention
■
For business
transactions provided certain conditions are met
■
If it is contained
in a witness statement and the collection is necessary to assess, process, or
settle an insurance claim
■
For identifying
injured, ill, or deceased persons and communicating with next of kin
■
If we have
reasonable grounds to believe an individual has been, is, or may be victim of
financial abuse
■
If it is reasonable
to expect collection and use with consent would compromise the availability or
the accuracy of the information and the collection is reasonable for purposes
related to investigating a breach of an agreement or a contravention of the laws
of Canada or a province
■
If disclosure is
required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records
■
If it was produced
by an individual in the course of their employment, business, or profession and
the collection is consistent with the purposes for which the information was
produced
■
If the collection
is solely for journalistic, artistic, or literary purposes
■
If the information
is publicly available and is specified by the regulations
4. WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share
information in specific situations described in this section and/or with the
following categories of third parties.
Vendors, Consultants, and Other Third-Party
Service Providers. We may share your
data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services
for us or on our behalf and require access to such information to do that work.
We have contracts in place with our third parties, which are designed to help
safeguard your personal information. This means that they cannot do anything
with your personal information unless we have instructed them to do it. They
will also not share your personal information with any organization apart from
us. They also commit to protect the data they hold on our behalf and to retain
it for the period we instruct. The categories of third parties we may share personal
information with are as follows:
■
Ad Networks
■
Affiliate Marketing
Programs
■
Cloud Computing
Services
■
Communication &
Collaboration Tools
■
Data Analytics
Services
■
Data Storage
Service Providers
■
Finance &
Accounting Tools
■
Government Entities
■
Order Fulfillment
Service Providers
■
Payment Processors
■
Performance
Monitoring Tools
■
Product Engineering
& Design Tools
■
Retargeting
Platforms
■
Sales &
Marketing Tools
■
Social Networks
■
Testing Tools
■
User Account
Registration & Authentication Services
■
Website Hosting
Service Providers
■
[Other]
We also may
need to share your personal information in the following situations:
■
Business Transfers. We may share or
transfer your information in connection with, or during negotiations of, any
merger, sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
■
When we use Google Analytics. We may share your information with Google Analytics to track and
analyze the use of the Services. The Google Analytics Advertising Features that
we may use include: [List Features]. To opt out
of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads
Settings and Ad Settings for mobile apps. Other opt
out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit
the Google Privacy & Terms page.
■
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs
(e.g., Google Maps API, Places API). To find out more about Google’s Privacy
Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain
information when you make location-specific requests. This includes: [List of Information Collected], and other similar
information. A full list of what we use information for can be found in this
section and in the previous section titled “HOW DO WE PROCESS YOUR
INFORMATION?” [We obtain and store on your device (“cache”) your location
for [#] months. You may revoke your consent anytime by contacting us at the
contact details provided at the end of this document.] The Google Maps
Platform APIs that we use store and access cookies and other information on
your devices. If you are a user currently in the European Economic Area (EU
countries, Iceland, Liechtenstein and Norway) or the United Kingdom, please
take a look at our Cookie Notice, which can be found at this link: [Cookie Notice URL].
■
Affiliates. We may share your
information with our affiliates, in which case we will require those affiliates
to honor this privacy notice. Affiliates include our parent company and any
subsidiaries, joint venture partners, or other companies that we control or
that are under common control with us.
■
Business Partners. We may share your
information with our business partners to offer you certain products, services,
or promotions.
■
Other Users. When you share
personal information (for example, by posting comments, contributions, or other
content to the Services) or otherwise interact with public areas of the
Services, such personal information may be viewed by all users and may be
publicly made available outside the Services in perpetuity. If you interact
with other users of our Services and register for our Services through a social
network (such as Facebook), your contacts on the social network will see your
name, profile photo, and descriptions of your activity. Similarly, other users
will be able to view descriptions of your activity, communicate with you within
our Services, and view your profile.
■
[Offer Wall. Our
application(s) may display a third-party hosted “offer wall.” Such an offer
wall allows third-party advertisers to offer virtual currency, gifts, or other
items to users in return for the acceptance and completion of an advertisement
offer. Such an offer wall may appear in our application(s) and be displayed to
you based on certain data, such as your geographic area or demographic
information. When you click on an offer wall, you will be brought to an
external website belonging to other persons and will leave our application(s).
A unique identifier, such as your user ID, will be shared with the offer wall
provider in order to prevent fraud and properly credit your account with the
relevant reward.]
5. WHAT IS OUR
STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not
responsible for the safety of any information that you share with third parties
that we may link to or who advertise on our Services, but are not affiliated
with, our Services.
The
Services, [including our offer wall], may link
to third-party websites, online services, or mobile applications and/or contain
advertisements from third parties that are not affiliated with us and which may
link to other websites, services, or applications. Accordingly, we do not make
any guarantee regarding any such third parties, and we will not be liable for
any loss or damage caused by the use of such third-party websites, services, or
applications. The inclusion of a link towards a third-party website, service,
or application does not imply an endorsement by us. We cannot guarantee the
safety and privacy of data you provide to any third parties. Any data collected
by third parties is not covered by this privacy notice. We are not responsible
for the content or privacy and security practices and policies of any third
parties, including other websites, services, or applications that may be linked
to or from the Services. You should review the policies of such third parties
and contact them directly to respond to your questions.
6. DO WE USE
COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies
and other tracking technologies to collect and store your information.
We may use
cookies and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie
Notice: [Cookie Notice URL].
7. HOW DO WE HANDLE
YOUR SOCIAL LOGINS?
In Short: If you choose to
register or log in to our Services using a social media account, we may have
access to certain information about you.
Our Services
offer you the ability to register and log in using your third-party social
media account details (like your Facebook or Twitter logins). Where you choose
to do this, we will receive certain profile information about you from your
social media provider. The profile information we receive may vary depending on
the social media provider concerned, but will often include your name, email
address, friends list, and profile picture, as well as other information you
choose to make public on such a social media platform.
[If you log in using Facebook, we may also request access to other permissions
related to your account, such as your friends, check-ins, and likes, and you
may choose to grant or deny us access to each individual permission.]
We will use
the information we receive only for the purposes that are described in this
privacy notice or that are otherwise made clear to you on the relevant
Services. Please note that we do not control, and are not responsible for,
other uses of your personal information by your third-party social media
provider. We recommend that you review their privacy notice to understand how
they collect, use and share your personal information, and how you can set your
privacy preferences on their sites and apps.
8. IS YOUR
INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer,
store, and process your information in countries other than your own.
Our servers
are located in[Country].
If you are accessing our Services from outside[Country], please be aware that your information may
be transferred to, stored, and processed by us in our facilities and by those
third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?" above), in[Country], and other countries.
If you are a
resident in the European Economic Area (EEA), United Kingdom (UK), or
Switzerland, then these countries may not necessarily have data protection laws
or other similar laws as comprehensive as those in your country. However, we
will take all necessary measures to protect your personal information in
accordance with this privacy notice and applicable law.
European
Commission's Standard Contractual Clauses:
We have
implemented measures to protect your personal information, including by using
the European Commission's Standard Contractual Clauses for transfers of
personal information between our group companies and between us and our
third-party providers. These clauses require all recipients to protect all
personal information that they process originating from the EEA or UK in
accordance with European data protection laws and regulations. Our Data
Processing Agreements that include Standard Contractual Clauses are available
here: [Standard Contractual Clauses URL]. We
have implemented similar appropriate safeguards with our third-party service
providers and partners and further details can be provided upon request.
Binding
Corporate Rules:
These
include a set of Binding Corporate Rules ("BCRs") established and
implemented by us. Our BCRs have been recognized by EEA and UK data protection
authorities as providing an adequate level of protection to the personal information
we process internationally. You can find a copy of our BCRs here: [BCRs URL].
[EU-US]and[Swiss-US] Privacy
Shield Framework[s]
We and the
following entities and subsidiaries: [List of
Entities/Subsidiaries] comply with the[EU-US] and[Swiss-US]Privacy
Shield Framework[s] as set forth by the US
Department of Commerce regarding the collection, use, and retention of personal
information transferred from [the European Union (EU)],
[the UK], and[Switzerland]to
the United States. Although Privacy Shield is no longer considered a valid
transfer mechanism for the purposes of [EU]and [Swiss] data
protection law, in light of the judgment of the Court of Justice of the
European Union in Case C-311/18 and opinion of the Federal Data Protection and
Information Commissioner of Switzerland dated 8 September 2020, we will
continue to comply with the principles of the [EU-US]and [Swiss-US] Privacy
Shield Framework[s]. Learn more about the Privacy
Shield program. To view our
certification, please visit[Privacy Shield Certification URL].
We adhere to
and comply with the Privacy Shield Principles when processing personal
information from[the
EU], [UK], or
[Switzerland]. If we have received your personal information in the
United States and subsequently transfer that information to a third party
acting as our agent, and such third party agent processes your personal
information in a manner inconsistent with the Privacy Shield Principles, we will
remain liable unless we can prove we are not responsible for the event giving
rise to the damage.
With respect
to personal information received or transferred pursuant to the Privacy Shield
Framework[s],we
are subject to the investigatory and enforcement powers of the US Federal Trade
Commission ("FTC"). In certain situations, we may be required to
disclose personal information in response to lawful requests by public
authorities, including to meet national security or law enforcement requirements.
If you have
any questions or concerns relating to our Privacy Shield certification, please
write to us at the contact details below. We commit to resolving any complaints
or disputes about our collection and use of your personal information under the
Privacy Shield.[However,
if you have an unresolved complaint in connection with our certification,we commit to cooperating
with the panel established by [the EU data protection authorities (DPAs)], [the
UK Information Commissioner], and [the Swiss Federal Data Protection and
Information Commissioner], as applicable, and to comply with the advice given
by them in respect of the complaint. See the following list of EU DPAs. / However, if you have an unresolved complaint in
connection with our certification, you may contact our independent dispute
resolution provider based in the [EU/United States], [Dispute Resolution
Provider Name]. Please visit [Dispute Resolution Provider URL] for more
information or to file a complaint. These services are provided to you free of
charge.]
In limited
situations,[EU], [UK], and [Swiss]individuals may seek redress from the Privacy
Shield Panel, a binding arbitration mechanism.
Please be
sure to review the following sections of this privacy notice for additional
details relevant to our participation in the
[EU-US]and [Swiss-US] Privacy Shield:
■
WHAT INFORMATION DO WE COLLECT?To learn more about the types of personal data we collect.
■
HOW DO WE PROCESS YOUR INFORMATION?To learn more about the purposes for which we collect and use personal
information about you.
■
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?To learn more about the type or identity of third parties to which we
disclose personal information, and the purposes for which we do so.
■
WHAT ARE YOUR PRIVACY RIGHTS?To learn more about the right of individuals to access their personal
data.
9. HOW LONG DO WE
KEEP YOUR INFORMATION?
In Short: We keep your
information for as long as necessary to fulfill the purposes outlined in this
privacy notice unless otherwise required by law.
We will only
keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting, or other legal requirements). No
purpose in this notice will require us keeping your personal information for
longer than [the period of time in which users have an
account with us / [#] months past the
termination of the user’s account / [#] months past the start of the idle
period of the user’s account / other].
When we have
no ongoing legitimate business need to process your personal information, we
will either delete or anonymize such information, or, if this is not possible
(for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it
from any further processing until deletion is possible.
10. HOW DO WE KEEP
YOUR INFORMATION SAFE?
In Short: We aim to protect
your personal information through a system of organizational and technical
security measures.
We have
implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your
information, no electronic transmission over the Internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security and improperly collect, access, steal,
or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a
secure environment.
11. DO WE COLLECT
INFORMATION FROM MINORS?
In Short: We do not
knowingly collect data from or market to children under 18 years of age.
We do not
knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the
parent or guardian of such a minor and consent to such minor dependent’s use of
the Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you
become aware of any data we may have collected from children under age 18,
please contact us at[Email Address].
12. WHAT ARE YOUR
PRIVACY RIGHTS?
In Short: In some regions,
such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and
Canada, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any time.
In some
regions (like the EEA, UK, Switzerland, and Canada), you have certain rights
under applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal
information; (iv) if applicable, to data portability; and (v) not to be subject
to automated decision-making. In certain circumstances, you may also have the
right to object to the processing of your personal information. You can make
such a request by contacting us by using the contact details provided in the
section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will
consider and act upon any request in accordance with applicable data protection
laws.
If you are
located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are
located in Switzerland, you may contact the Federal
Data Protection and Information Commissioner.
Withdrawing your
consent: If we are relying on your consent to
process your personal information, which may be express and/or implied consent
depending on the applicable law, you have the right to withdraw your consent at
any time. You can withdraw your consent at any time by contacting us by using
the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?" below or
updating your preferences.
However,
please note that this will not affect the lawfulness of the processing before
its withdrawal nor, when applicable law allows, will it affect the processing
of your personal information conducted in reliance on lawful processing grounds
other than consent.
Opting out of marketing and promotional
communications: You can unsubscribe
from our marketing and promotional communications at any time by clicking on
the unsubscribe link in the emails that we send, replying “STOP” or
“UNSUBSCRIBE” to the SMS messages that we send, [Other]
or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?" below. You
will then be removed from the marketing lists — however, we may still
communicate with you, for example to send you service-related messages that are
necessary for the administration and use of your account, to respond to service
requests, or for other non-marketing purposes.
Account Information
If you would
at any time like to review or change the information in your account or
terminate your account, you can:
■
Log in to your
account settings and update your user account.
■
Contact us using
the contact information provided.
■
[Other]
Upon your
request to terminate your account, we will deactivate or delete your account
and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with
any investigations, enforce our legal terms and/or comply with applicable legal
requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer,
you can usually choose to set your browser to remove cookies and to rejectcookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our Services.
You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie
Notice:[Cookie
Notice URL].
If you have
questions or comments about your privacy rights, you may email us at [Email Address].
13. CONTROLS FOR
DO-NOT-TRACK FEATURES
Most web
browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not
currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will
inform you about that practice in a revised version of this privacy notice.
14. DO UNITED
STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a
resident of California, Colorado, Connecticut, Utah, or Virginia, you are
granted specific rights regarding access to your personal information.
What categories of personal information do we
collect?
We have
collected the following categories of personal information in the past twelve
(12) months:
Category
Examples
Collected
A.
Identifiers
Contact
details, such as real name, alias, postal address, telephone or mobile
contact number, unique personal identifier, online identifier, Internet
Protocol address, email address, and account name
[YES/NO]
B.
Personal information as defined in the California Customer Records statute
Name,
contact information, education, employment, employment history, and financial
information
[YES/NO]
C.
Protected classification characteristics under state or federal law
Gender and
date of birth
[YES/NO]
D.
Commercial information
Transaction
information, purchase history, financial details, and payment information
[YES/NO]
E.
Biometric information
Fingerprints
and voiceprints
[YES/NO]
F.
Internet or other similar network activity
Browsing
history, search history, online behavior, interest data, and interactions
with our and other websites, applications, systems, and advertisements
[YES/NO]
G.
Geolocation data
Device
location
[YES/NO]
H. Audio,
electronic, visual, thermal, olfactory, or similar information
Images and
audio, video or call recordings created in connection with our business
activities
[YES/NO]
I.
Professional or employment-related information
Business
contact details in order to provide you our Services at a business level or
job title, work history, and professional qualifications if you apply for a
job with us
[YES/NO]
J.
Education information
Student
records and directory information
[YES/NO]
K.
Inferences drawn from collected personal information
Inferences
drawn from any of the collected personal information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics
[YES/NO]
L.
Sensitive personal information
Account
login information, drivers’ licenses, health data, precise geolocation,
racial or ethnic origin, religious or philosophical beliefs, and sex life or
sexual orientation
[YES/NO]
We will use and retain the collected
■
Category A - [Retention Period]
■
Category B - [Retention Period]
■
Category C - [Retention Period]
■
Category D - [Retention Period]
■
Category E - [Retention Period]
■
Category F - [Retention Period]
■
Category G - [Retention Period]
■
Category H - [Retention Period]
■
Category I - [Retention Period]
■
Category J - [Retention Period]
■
Category K - [Retention Period]
■
Category L - [Retention Period]
We may also
collect other personal information outside of these categories through
instances where you interact with us in person, online, or by phone or mail in
the context of:
■
Receiving help
through our customer support channels;
■
Participation in
customer surveys or contests; and
■
Facilitation in the
delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about
how we use your personal information in the section, “HOW CAN YOU CONTACT US ABOUT
THIS NOTICE?”
We collect
and share your personal information through:
■
Targeting
cookies/Marketing cookies
■
Social media
cookies
■
Beacons/Pixels/Tags
■
Click redirects: [Click Redirects]
■
Social media
plugins: [Social Media Plugins]. We use social
media features, such as a "Like" button, and widgets, such as a
"Share" button in our Services. Such features may process your
Internet Protocol (IP) address and track which page you are visiting on our
website. We may place a cookie to enable the feature to work correctly. If you
are logged in on a certain social media platform and you interact with a widget
or button belonging to that social media platform, this information may be
recorded to your profile of such social media platform. To avoid this, you
should log out from that social media platform before accessing or using the
Services. Social media features and widgets may be hosted by a third party or
hosted directly on our Services. Your interactions with these features are
governed by the privacy notices of the companies that provide them. By clicking
on one of these buttons, you agree to the use of this plugin and consequently
the transfer of personal information to the corresponding social media service.
We have no control over the essence and extent of these transmitted data or
their additional processing.
■
[Other]
Will your information be shared with anyone else?
We may
disclose your personal information with our service providers pursuant to a
written contract between us and each service provider. Learn more about who we
disclose personal information to in the section, "WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?"
We may use
your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration.
This is not considered to be "selling" of your personal information.
We have
disclosed the following categories of personal information to third parties for
a business or commercial purpose in the preceding twelve (12) months:
■
Category A.
Identifiers
■
Category B.
Personal information, as defined in the California Customer Records law
■
Category C.
Characteristics of protected classifications under state or federal law
■
Category D.
Commercial information
■
Category E.
Biometric information
■
Category F.
Internet or other electronic network activity information
■
Category G.
Geolocation data
■
Category H. Audio,
electronic, visual, and similar information
■
Category I.
Professional or employment-related information
■
Category J.
Education information
■
Category K.
Inferences drawn from collected personal information
■
Category L.
Sensitive personal information
The
categories of third parties to whom we disclosed personal information for a
business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?"
We
have not sold or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. / We have
sold or shared the following categories of personal information to third
parties in the preceding twelve (12) months:
■
Category
A. Identifiers
■
Category
B. Personal information, as defined in the California Customer Records law
■
Category
C. Characteristics of protected classifications under state or federal law
■
Category
D. Commercial information
■
Category
E. Biometric information
■
Category
F. Internet or other electronic network activity information
■
Category
G. Geolocation data
■
Category
H. Audio, electronic, visual, and similar information
■
Category
I. Professional or employment-related information
■
Category
J. Education information
■
Category
K. Inferences drawn from collected personal information
■
Category
L. Sensitive personal information
The
categories of third parties to whom we sold personal information are:
■
Ad
Networks
■
Affiliate
Marketing Programs
■
Data
Analytics Services
■
Retargeting
Platforms
■
Social
Networks
■
User
Account Registration & Authentication Services
■
[Other]
The
categories of third parties to whom we shared personal information with are:
■
Ad
Networks
■
Affiliate
Marketing Programs
■
Data
Analytics Services
■
Retargeting
Platforms
■
Social
Networks
■
User
Account Registration & Authentication Services
■
[Other]]
California Residents
California
Civil Code Section 1798.83, also known as the "Shine The Light" law,
permits our users who are California residents to request and obtain from us,
once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California
resident and would like to make such a request, please submit your request in
writing to us using the contact information provided below.
If you are
under 18 years of age, reside in California, and have a registered account with
Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact
us using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We
will make sure the data is not publicly displayed on the Services, but please
be aware that the data may not be completely or comprehensively removed from
all our systems (e.g., backups, etc.).
CCPA Privacy
Notice
This section
applies only to California residents. Under the California Consumer Privacy Act
(CCPA), you have the rights listed below.
The
California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a
temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other
individuals are defined as "non-residents."
If this
definition of "resident" applies to you, we must adhere to certain
rights and obligations regarding your personal information.
Your rights with respect to your personal data
Right to
request deletion of the data — Request to delete
You can ask
for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not
limited to) the exercise by another consumer of his or her right to free
speech, our compliance requirements resulting from a legal ob`
Depending on
the circumstances, you have a right to know:
■
whether we collect
and use your personal information;
■
the categories of
personal information that we collect;
■
the purposes for
which the collected personal information is used;
■
whether we sell or
share your personal information to third parties;
■
the categories of
personal information that we sold, shared, or disclosed for a business purpose;
■
the categories of
third parties to whom the personal information was sold, shared, or disclosed
for a business purpose;
■
the business or
commercial purpose for collecting, sharing, or selling personal information;
and
■
the specific pieces
of personal information we collected about you.
In
accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or
to re-identify individual data to verify a consumer request.
Right to
Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not
discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
[We do not process consumer’s sensitive personal
information. / If the business collects any of the following:
■
social
security information, drivers’ licenses, state ID cards, passport numbers
■
account
login information
■
credit
card numbers, financial account information, or credentials allowing access to
such accounts
■
precise
geolocation
■
racial
or ethnic origin, religious or philosophical beliefs, union membership
■
the
contents of email and text, unless the business is the intended recipient of
the communication
■
genetic
data, biometric data, and health data
■
data
concerning sexual orientation and sex life
you have the right to direct that business to limit its use
of your sensitive personal information to that use which is necessary to
perform the Services.
Once a business receives your request, they are no longer
allowed to use or disclose your sensitive personal information for any other
purpose unless you provide consent for the use or disclosure of sensitive
personal information for additional purposes.
Please note that sensitive personal Information that is
collected or processed without the purpose of inferring characteristics about a
consumer is not covered by this right, as well as the publicly available
information.
To exercise your right to limit use and disclosure of
sensitive personal Information, please email [Email Address] or visit: [DSAR
Form URL].]
Verification
process
Upon
receiving your request, we will need to verify your identity to determine you
are the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we
can match it with information you have previously provided us. For instance,
depending on the type of request you submit, we may ask you to provide certain
information so that we can match the information you provide with the
information we already have on file, or we may contact you through a
communication method (e.g., phone or email) that you have previously provided
to us. We may also use other verification methods as the circumstances dictate.
We will only
use personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if
we cannot verify your identity from the information already maintained by us,
we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes. We will
delete such additionally provided information as soon as we finish verifying
you.
Other
privacy rights
■
You may object to
the processing of your personal information.
■
You may request
correction of your personal data if it is incorrect or no longer relevant, or
ask to restrict the processing of the information.
■
You can designate
an authorized agent to make a request under the CCPA on your behalf. We may
deny a request from an authorized agent that does not submit proof that they
have been validly authorized to act on your behalf in accordance with the CCPA.
■
[You may request to opt out from future
selling or sharing of your personal information to third parties. Upon
receiving an opt-out request, we will act upon the request as soon as feasibly
possible, but no later than fifteen (15) days from the date of the request
submission.]
[You
can opt out from the selling or sharing of your personal information by
disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell
or Share My Personal Information link on our homepage.]
To exercise
these rights, you can contact us by visiting [DSAR
Form URL], by email at [Email Address],
by calling toll-free at [Phone Number], by
visiting [Contact Form URL], or by referring to
the contact details at the bottom of this document. If you have a complaint
about how we handle your data, we would like to hear from you.
Financial
Incentives
"Financial
incentive" means a program, benefit, or other offering, including payments
to consumers as compensation, for the disclosure, deletion, sharing, or sale of
personal information.
The law
permits financial incentives or a price or service difference if it is
reasonably related to the value of the consumer’s data. A business must be able
to explain how the financial incentive or price or service difference is
reasonably related to the value of the consumer’s data. The explanation must
include:
■
a good-faith
estimate of the value of the consumer’s data that forms the basis for offering
the financial incentive or price or service difference; and
■
a description of
the method the business used to calculate the value of the consumer’s data.
We may
decide to offer a financial incentive (e.g., price or service difference) in
exchange for the retention, or sale or sharing of a consumer’s personal
information.
If we decide
to offer a financial incentive, we will notify you of such financial incentive
and explain the price difference, as well as material terms of the financial
incentive or price of service difference, including the categories of personal
information that are implicated by the financial incentive or price or service
difference.
If you
choose to participate in the financial incentive you can withdraw from the
financial incentive at any time by emailing us at
[Email Address], by calling us toll-free at [Phone
Number], by visiting [Contact Form URL],
or by referring to the contact details at the bottom of this document.
Metrics
Our metrics
for all CCPA requests received for the previous calendar year can be found
here: [Metrics URL].
Colorado Residents
This section
applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you
have the rights listed below. However, these rights are not absolute, and in
certain cases, we may decline your request as permitted by law.
■
Right to be
informed whether or not we are processing your personal data
■
Right to access
your personal data
■
Right to correct
inaccuracies in your personal data
■
Right to request
deletion of your personal data
■
Right to obtain a
copy of the personal data you previously shared with us
■
Right to opt out of
the processing of your personal data if it is used for targeted advertising,
the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects (“profiling”)
[We
sell personal data to third parties or process personal data for targeted
advertising. You can opt out from the selling of your personal data, targeted
advertising, or profiling by disabling cookies in Cookie Preference Settings.] To submit a request to exercise these rights described above, please
email [Email Address] or visit [DSAR Form URL].
If we
decline to take action regarding your request and you wish to appeal our
decision, please email us at [Email Address]. Within forty-five (45) days of
receipt of an appeal, we will inform you in writing of any action taken or not
taken in response to the appeal, including a written explanation of the reasons
for the decisions.
Connecticut Residents
This section
applies only to Connecticut residents. Under the Connecticut Data Privacy Act
(CTDPA), you have the rights listed below. However, these rights are not
absolute, and in certain cases, we may decline your request as permitted by
law.
■
Right to be
informed whether or not we are processing your personal data
■
Right to access
your personal data
■
Right to correct
inaccuracies in your personal data
■
Right to request
deletion of your personal data
■
Right to obtain a
copy of the personal data you previously shared with us
■
Right to opt out of
the processing of your personal data if it is used for targeted advertising,
the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects (“profiling”)
[We
sell personal data to third parties or process personal data for targeted
advertising. You can opt out from the selling of your personal data, targeted
advertising, or profiling by disabling cookies in Cookie Preference Settings.] To submit a request to exercise these rights described above, please
email [Email Address] or visit [DSAR Form URL].
If we
decline to take action regarding your request and you wish to appeal our
decision, please email us at [Email Address].
Within sixty (60) days of receipt of an appeal, we will inform you in writing
of any action taken or not taken in response to the appeal, including a written
explanation of the reasons for the decisions.
Utah Residents
This section
applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), you
have the rights listed below. However, these rights are not absolute, and in
certain cases, we may decline your request as permitted by law.
■
Right to be
informed whether or not we are processing your personal data
■
Right to access
your personal data
■
Right to request
deletion of your personal data
■
Right to obtain a
copy of the personal data you previously shared with us
■
Right to opt out of
the processing of your personal data if it is used for targeted advertising or
the sale of personal data
[We
sell personal data to third parties or process personal data for targeted
advertising. You can opt out from the selling of your personal data, targeted
advertising, or profiling by disabling cookies in Cookie Preference Settings.] To submit a request to exercise these rights described above, please
email [Email Address] or visit [DSAR Form URL].
Virginia Residents
Under the
Virginia Consumer Data Protection Act (VCDPA):
"Consumer"
means a natural person who is a resident of the Commonwealth acting only in an
individual or household context. It does not include a natural person acting in
a commercial or employment context.
"Personal
data" means any information that is linked or reasonably linkable to an
identified or identifiable natural person. "Personal data" does not
include de-identified data or publicly available information.
"Sale of
personal data" means the exchange of personal data for monetary
consideration.
If this definition
of "consumer" applies to you, we must adhere to certain rights and
obligations regarding your personal data.
Your rights
with respect to your personal data
■
Right to be
informed whether or not we are processing your personal data
■
Right to access your
personal data
■
Right to correct
inaccuracies in your personal data
■
Right to request
deletion of your personal data
■
Right to obtain a
copy of the personal data you previously shared with us
■
Right to opt out of
the processing of your personal data if it is used for targeted advertising,
the sale of personal data, or profiling in furtherance of decisions that
produce legal or similarly significant effects (“profiling”)
[We
sell personal data to third parties or process personal data for targeted
advertising. Please see the following section to find out how you can opt out
from further selling or sharing of your personal data for targeted advertising or profiling purposes.]
Exercise
your rights provided under the Virginia VCDPA
[You
can opt out from the selling of your personal data, targeted advertising, or
profiling by disabling cookies in Cookie Preference Settings.]
You may
contact us by email at [Email Address] or visit
[Contact Form URL].
If you are
using an authorized agent to exercise your rights, we may deny a request if the
authorized agent does not submit proof that they have been validly authorized
to act on your behalf.
Verification
process
We may
request that you provide additional information reasonably necessary to verify
you and your consumer's request. If you submit the request through an
authorized agent, we may need to collect additional information to verify your
identity before processing your request.
Upon
receiving your request, we will respond without undue delay, but in all cases,
within forty-five (45) days of receipt.
The response period may be extended once by forty-five (45) additional
days when reasonably necessary. We will
inform you of any such extension within the initial 45-day response period,
together with the reason for the extension.
Right to
appeal
If we
decline to take action regarding your request, we will inform you of our
decision and reasoning behind it. If you wish to appeal our decision, please
email us at [Email Address]. Within sixty (60)
days of receipt of an appeal, we will inform you in writing of any action taken
or not taken in response to the appeal, including a written explanation of the
reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.
15. DO OTHER
REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have
additional rights based on the country you reside in.
Australia and New Zealand
We collect
and process your personal information under the obligations and conditions set
by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy
Act).
This privacy
notice satisfies the notice requirements defined in both Privacy Acts, in
particular: what personal information we collect from you, from which sources,
for which purposes, and other recipients of your personal information.
If you do
not wish to provide the personal information necessary to fulfill their
applicable purpose, it may affect our ability to provide our services, in
particular:
■
offer you the
products or services that you want
■
manage your account
with us
■
respond to or help
with your requests
■
confirm your
identity and protect your account
At any time,
you have the right to request access to or correction of your personal
information. You can make such a request by contacting us by using the contact
details provided in the section “HOW CAN YOU REVIEW, UPDATE,
OR DELETE THE DATA WE COLLECT FROM YOU?”
If you
believe we are unlawfully processing your personal information, you have the
right to submit a complaint about a breach of the Australian Privacy Principles
to the Office of the Australian Information Commissioner and for a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time,
you have the right to request access to or correction of your personal
information. You can make such a request by contacting us by using the contact
details provided in the section “HOW CAN YOU REVIEW, UPDATE,
OR DELETE THE DATA WE COLLECT FROM YOU?”
If you are
unsatisfied with the manner in which we address any complaint with regard to
our processing of personal information, you can contact the office of the regulator,
the details of which are:
The
Information Regulator (South Africa)
General
enquiries: enquiries@inforegulator.org.za
Complaints
(complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
16. DO WE MAKE
UPDATES TO THIS NOTICE?
In Short: Yes, we will update
this notice as necessary to stay compliant with relevant laws.
We may
update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will
be effective as soon as it is accessible. If we make material changes to this
privacy notice, we may notify you either by prominently posting a notice of
such changes or by directly sending you a notification. We encourage you to
review this privacy notice frequently to be informed of how we are protecting
your information.
17. HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?
If you have
questions or comments about this notice, you may contact our Data Protection
Officer (DPO), [DPO Name], by email at [Email Address], by phone at [Phone
Number], or by post to:
[Company
Name]
[DPO
Name]
[Street
Address]
[City,
State ZIP Code]
[Country]
If you are a
resident in the European Economic Area or Switzerland, we are the "data
controller" of your personal information. We have appointed [EEA Representative Name] to be our representative in
the EEA and Switzerland. You can contact them directly regarding our processing
of your information, by email at [Email Address],
by visiting [EEA Representative URL], by phone
at [Phone Number], or by post to:
[Street
Address]
[City,
State ZIP Code]
[Country]
Swiss
Representative
[Swiss
Representative Name]
[Street
Address]
[City,
State ZIP Code]
[Country]
Phone: [Phone Number]
Fax: [Fax Number]
[Swiss
Representative URL]
If you are a
resident in the United Kingdom, we are the "data controller" of your
personal information. We have appointed [UK
Representative Name] to be our representative in the UK. You can contact
them directly regarding our processing of your information, by email at [Email Address], by visiting [UK
Representative URL], by phone at [Phone Number],
or by post to:
[Street
Address]
[City,
State ZIP Code]
[Country]
If you have
any further questions or comments, you may also contact us by post at the
following corporate address:
[Company
Name]
[Street
Address]
[City,
State ZIP Code]
[Country]
Phone: [Phone Number]
Fax: [Fax Number]
18. HOW CAN YOU
REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the
applicable laws of your country, you may have the right to request access to
the personal information we collect from you, change that information, or
delete it. To request to review, update, or delete your personal information,
please visit: [DSAR Form URL].
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30 min Meeting
08:00 AM - 08:30 AM, Thursday, Nov 24, 2024
Indian Standard Time
Shahanab
