Last updated March 31, 2021
TABLE OF CONTENT
1. WHAT INFORMATION DO WE COLLECT?
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:
Personal Information you provide to us. In Short: We collect Personal Information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect Personal Information that you voluntarily provide to us when registering at the Services or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or Apps (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.
The Personal Information that we collect depends on the context of your interactions with us and the Services or Apps, the choices you make and the products and features you use. The Personal Information we collect can include the following:
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 IP address and/or browser and device characteristics — is collected automatically when you visit our Services or Apps.
We automatically collect certain information when you visit, use or navigate the Services or Apps. 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 or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Services or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
Email Open/Click Information. We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
Information collected through our Apps
In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.
If you use our Apps, we may also collect the following information:
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use Personal Information collected via our Services or Apps for a variety of business purposes described below. We process your Personal Information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
Marketing and Communications. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email [or telephone number], we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails [and/or text messages] you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
More specifically, we may need to process your data or share your Personal Information in the following situations:
4. 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 the USA. If you are accessing our Services or Apps from outside the USA, 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 "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in the USA, and other countries.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, 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.
6. 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, but no security measures are 100% secure.
We have implemented commercially reasonable technical and organizational security measures designed to protect the security of any Personal Information we process. However, please remember that we cannot guarantee that the internet itself is 100% secure. Although we will use commercially reasonable efforts to protect your Personal Information, transmission of Personal Information to and from our Services or Apps is at your own risk. You should only access the services within a secure environment.
7. THIRD-PARTY SERVICES
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 16 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services or Apps, 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 or Apps. 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 have collected from children under age 18, please contact us at email@example.com.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you may 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 European Economic Area), you may 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; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Personal Information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm. If you have questions or comments about your privacy rights, you may email us at firstname.lastname@example.org.
11. WHAT ARE YOUR CHOICES?
In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided.
12. ONLINE TRACKING AND DO-NOT-TRACK SIGNALS
13. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Rush Sadiwala, by email at email@example.com, or by post to:
800 Avenue of the Americas, Apt 21C
New York, NY 10001