Last Updated: 4th May 2022
PERSONAL INFORMATION WE COLLECT AND USE
The types of information we collect when you use the Site depend on the features you use on the Site. “Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, device, or household.
- Identifiers, which may include name, address, Internet Protocol address, or email address. These are sourced directly from you or indirectly from you (e.g., from observing your actions on the Site). They are used to fulfill or meet the reason you provided the information, to contact you in relation to our Site, to respond to an inquiry, or to screen for potential risk or fraud. We disclose this information for business purposes to internet service providers and administrative service providers.
- Professional or employment-related information, which may include name, email address, contact information, and affiliated company. We source this information directly from you. We use this information to fulfill or meet the reason you provided the information, to contact you in relation to our Site, to respond to an inquiry, or to screen for potential risk or fraud. We disclose this information for business purposes to internet service providers and administrative service providers.
- Inferences drawn from other personal information, which may include a profile reflecting a person’s preferences, interests, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We source this information directly or indirectly from you, (e.g., from observing your actions on our Site). We use this information to fulfill or meet the reason you provided the information. We do not disclose this information to third parties.
COOKIES, ONLINE TRACKING, AND ADS
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information:
- Directly from you. You may give us your personal information when you do any of the following:
- Access or use the Site; or
- Fill out a contact form.
- When you interact with the Site. As you interact with and use the Site, we may automatically collect your personal information, e.g. your internet, technical or other similar network activity. We may also collect personal information by using website cookies.
- Third parties or publicly available sources. We may receive your personal information from third parties, which include:
- Internet, technical or other similar network activity from analytics providers, advertising networks and social media platforms; and
- Identifiers and commercial information from providers of technical services.
SHARING YOUR PERSONAL INFORMATION
We may share your personal information in the following ways:
- We may share your information with domestic or foreign third parties including our agents, service providers, and consultants as needed for them to provide business-related services to us. Such third parties may manage our customer information and perform services on our behalf, such as website hosting, fraud monitoring, email or mail delivery and administration, or data analysis, etc. We ask third parties with whom we share your information to confirm that their privacy practices are consistent with ours and applicable law, and we provide them with only the information they need in order to perform their services for us.
- We may share your information or combine your information with publicly available information when we team up with other domestic or foreign promotional partners to jointly offer or provide products, services, contests, or promotions to our customers, or otherwise to enhance and personalize your experience.
- Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
HOW WE RESPOND TO DO NOT TRACK SIGNALS
The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We therefore do not recognize DNT signals and do not respond to them.
We will retain your information for as long as needed to provide you services and to comply with our accounting and legal obligations, resolve disputes, and enforce our agreements.
We take reasonable physical, electronic and managerial measures to safeguard and secure any personal information you provide to us. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure due to the inherent risks of data transmission over the Internet. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Site or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. We may post a notice via our Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
CONSENT TO TRANSFER
LAWFUL BASES ON WHICH WE PROCESS YOUR PERSONAL INFORMATION
In processing personal information, we may rely upon the following lawful bases:
- Consent. We may process personal information with the consent of the individual whose data is being processed and/or in reliance upon the consent of the administrator of the account, who must affirm that s/he has obtained appropriate consent from all participants.
- Contract. When we enter a contract with you and/or an administrator for your account, we process personal information on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract. This is necessary for us to provide the Websites to you.
- As required by law. We may process personal information as required to comply with legal obligations to which we are subject for the purpose of compliance with U.S., European Union, United Kingdom, or Swiss public, governmental, judicial or other regulatory authorities.
- For legitimate business purposes. This includes but is not limited to legal compliance and the purposes described above.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
INDIVIDUAL DATA RIGHTS
Depending on your residence, the rights available to you may differ in some respects. We will respond to any rights request in accordance with local legal regulations applicable to you.
Right of access
- You may have the right to get confirmation about whether or not your personal information is being processed. If so, you have the right to access the personal information and other information, such as the purposes, the categories of personal information, the recipients (or categories of recipients) to whom the personal information have been or will be disclosed – you may obtain our list of service providers who may receive your personal information on written request , for particular recipients in third countries or international organizations, where possible, the predicted period that the personal information will be stored, or, if not possible, the criteria used to determine that period, your rights, etc.
Right to rectification or to correct inaccurate personal information
- You may have the right to rectify, correct, or complete your personal information if inaccurate or incomplete.
Right to erasure (‘right to be forgotten’)
- You may have the right to the erasure of your personal information in certain circumstances.
- This right shall not apply to the extent that processing is necessary for the below purposes.
- For exercising the right of freedom of expression and information
- For compliance with a legal obligation which requires processing by a law to which we are subject
- For the performance of a task carried out in the public interest
- For the establishment, exercise or defense of our legal claims
Right to restriction of processing
- You may have the right to restrict the processing for the below reasons:
- You contest the accuracy of your personal information, for a period enabling us to verify the accuracy of the personal information
- The processing is unlawful and you oppose the erasure of the personal information and request the restriction of their use
- We no longer need the personal information for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims
- You exercised your right to object to processing pending the verification whether our legitimate grounds override yours
Right to data portability
- You may have the right to receive the personal information that you have given us, in a structured, commonly used and machine-readable format. You have the right to send that personal information to another controller, if the processing is based on consent pursuant or on a contract and is carried out by automated means.
Right to object
- You may have the right to object, on grounds relating to your particular situation, to processing of your personal information which is based on our legitimate purposes. We will stop processing the personal information unless we have compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. If personal information is processed for direct marketing purposes, including profiling, you may object at any time.
Right to opt out of the sale or sharing of your personal information to third parties
- Note that “sale” has particular definitions under certain laws. It includes where personal information is shared with third parties in exchange for monetary or other valuable consideration. “Sharing” also has particular definitions under certain laws, and is defined as making available personal information to a third party for cross-context behavioral advertising. We do not sell your personal information at this time, we do not share your personal information with third parties for their direct marketing purposes, and we do not sell the personal information of children under 16 years old.
Automated individual decision-making, including profiling
- You may have the right not to be subject to a decision based solely on automated processing, including profiling, except under certain exceptions under local law.
Right to withdraw consent
- Where the processing of personal information is based on your consent, you may have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.
Right to anonymity
- You may also have a right to request anonymity. This means that your personal information would not be collected or processed. If you choose to exercise this right, we may not be able to provide you with your requested goods or Services.
Right to lodge a complaint with a supervisory authority
The right not to be discriminated against for exercising rights mentioned above
We may offer various financial incentives from time to time. The terms of the financial incentive will be provided at the time you sign up for the financial incentive. You may withdraw from any of the financial incentives. We have calculated the value of the financial incentive by using the expense related to the offer, and the value of your data is the value of the offer presented to you
COLLECTION AND USE OF INFORMATION FROM CHILDREN UNDER THE AGE OF 18
The Site is not intended for use by persons under the age of 18. We do not knowingly collect information from visitors under the age of 18 and, in the event that we learn that a person under the age of 18 has provided us with personal information, we will delete such personal information.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email or by mail using the details provided below: