Effective Date 2/19/2021; Date Modified: 2/18/2021
Company is a corporation established in the United States and/or Canada and is currently offering its Services in United States and Canada.
PERSONAL INFORMATION PROCESSED
Through your use of our website/applications, we may collect personal information, including: Identifiers: contact information including your first and last name, email address, username, phone number, and home (postal) address, telephone number, bank account number(s), credit/debit card number(s).
- Professional or employment-related information: your company, job title, employment status, education.
- Commercial information: records of products or services purchased, obtained, or considered, or other purchasing or consuming records or behaviors.
- Publicly available information about you collected from third parties, e.g. postal service information for shipping address verification, records of real estate ownership or personal property.
- Internet or other electronic network activity information, including analytical data e.g., pages and products viewed, ads clicked on, emails from us that you opened, browser, operating system (“OS”), Internet Protocol (“IP”) address and device information, and any data collected by cookies. (See Sample Policies for cookies related language if in use) When using apps, we often gather information about your mobile device, referring/exit pages and URLs, domain names, landing pages, and other information. When you access our Services by or through a mobile device, we may receive or collect and store a unique identification number associated with your device, mobile carrier, device type and manufacturer, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates or similar information regarding the location of your mobile device.
PURPOSES OF THE PROCESSING
Your personal information may be processed for the following purposes:
- Compliance: to fulfil obligations provided by law and regulations.
- Account registration: to create an account with us.
- Customer services: to provide you with a response to your questions (e.g., concerning products and services).
- Fulfilling Services: to provide the services pursuant to our agreement with you.
- Marketing: to send marketing communications, e.g., news relating to our business, events, new products and services, and updates/news on existing products and services, or,
- to conduct market research.
PROTECTION OF PERSONAL INFORMATION
Your personal information will be processed in accordance with the principles of correctness, lawfulness, and transparency.
We maintain appropriate security, technical, and organizational measures that ensure a level of security appropriate to the risk of unauthorized access to, and accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, personal information transmitted, stored, or otherwise processed. We ensure that our third-party service providers who access or handle personal information on our behalf maintain the same level of safeguards.
Your personal information will be processed manually or electronically using automated tools that ensure the security and confidentiality of your personal information.
We will process only personal information necessary for the purposes described above. People authorized to process personal information will immediately delete or make anonymous personal information unnecessary for the above purposes.
If we have given you, or you have chosen, a password to access certain areas of our services, you are responsible for keeping the password confidential: you should not share your password with anyone and are responsible for any consequential damages arising from the sharing of that password.
DATA RETENTION PERIOD
Your personal information will be retained:
- for contractual purposes: for the entire duration of your use of our Services and following the withdrawal of your registration, for the period necessary for the purposes of the (i) establishment, exercise, or defense of legal claims and keeping accounting records of Company, and (ii) fulfilment of legal obligations applicable to us. Note that statute of limitations and other applicable laws may vary by jurisdiction.
- for sending newsletters, advertising material, and other communications on new products/services and updates/news on existing products/services, and for carrying out surveys, including on customer satisfaction: for 24 months from their collection, unless it is necessary by law to keep them longer.
The information will be deleted or rendered anonymous at the end of the periods identified above.
DISCLOSURE AND SALE OF PERSONAL INFORMATION
Personal information may be processed by our employees authorized to process personal information for the purposes described above. Third parties may process your personal information to perform other business purposes necessary to provide services to you, including:
- Service Providers. We may share your user information with providers who perform services on our behalf.
- Business Partners. We may share personal information about you with business partners that provide services and functionality.
- Legal Compliance. We may share personal information about you if we believe in good faith that disclosing information is necessary to comply with a valid legal process, governmental request, or applicable law; to investigate potential Terms of Service violations; to protect the rights of other users and visitors; or to detect and resolve fraud or security concerns.
- Sale of Personal Information. (Company) does not sell your personal information for monetary or other valuable consideration.
TRANSFER OF PERSONAL DATA
If Personal information is transferred outside of the United States of America and/or Canada, Company will take appropriate measures to ensure appropriate safeguards are in place to protect your personal information.
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
AGGREGATED PERSONAL INFORMATION
Company may conduct research on its customer demographics, interests and behaviors based on information supplied to us to be analyzed on an aggregate basis and will not identify you personally. The research complied may be shared with affiliates and/or business partners. Aggregated user statistics might also be shared with current and/or prospective business partners as well as with other third parties to describe our services and for other lawful purposes.
MANAGING THE PROCESSING OF YOUR PERSONAL INFORMATION
Residents of California have the following rights under the California Consumer Privacy Act (CCPA) related to data collected in the past twelve months:
- to request disclosure of the categories and specific pieces of your personal information collected.
- to request deletion of your personal information that has been collected (with exceptions).
- to request disclosure of the categories of personal information collected; the categories of sources from which the personal information is collected; the business or commercial purpose for collecting or selling personal information; the categories of third parties with whom the personal information is disclosed; and the specific pieces of personal information collected;
- to request disclosure of the categories of your personal information sold and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom your personal information was sold; and the categories of your personal information disclosed for a business purpose;
- to opt out of the sale of your personal information; and,
- nondiscrimination should you exercise your rights under the CCPA.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise your rights or to obtain more information, you may contact us:
- By email at: email@example.com
- By telephone at: 415-418-4006
- By US mail at: 575 Market Street, 4th Floor, San Francisco, CA, 94105