We at [COMPANY NAME]. (“[ALIAS]” “us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers. This Privacy Notice describes the types of information we collect from you when you visit our website and use our services (“Site” and “Services”, respectively). This Privacy Notice also explains how we may process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. “You” means any adult user of the Site and/or Services, or any parent or guardian of any minor whom you allow to use the Site and/or Services, and for whom you will be held strictly responsible.
[COMPANY NAME]. is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is [ADDRESS] and our registration number [REGISTRATION NUMBER].
“Personal Information” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
Privacy Notice Key Points
The key points listed below are presented in further detail throughout this Privacy Notice. These key points do not substitute the full Privacy Notice.
- Personal Information We Collect. When you sign up to a mailing list, register your product, make a purchase on the Site, or enter your information for other purposes, we collect certain Personal Information provided by you, such as your name, email address, phone number, postal address, and credit card details. If you contact us for questions or complaints, we will collect the information related to your inquiry. When you visit our Site, we automatically collect your IP address and operating system and about your use of the Site.
- How We Use the Information We Collect. We use the information (including Personal Information) we collect mainly to administer and provide the Site and Services, contact you with administrative information (including regulatory updates), contact you with marketing offers, subject to your consent if and to the extent required under applicable law and improve the Site and Services.
- Basis for Processing Your Personal Information. Processing your Personal Information is necessary for the provision of the Site and Services to you. Processing for the purposes of developing and enhancing our products and services, for analytics and usage analysis, for fraud prevention and security to send you marketing materials relating to our products and services and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue. We may also use your Personal Information for other marketing purposes based upon your consent, if and as applicable.
- Sharing the Personal Information We Collect. We may share the Personal Information we collect with our service providers and subcontractors who assist us in the operation of the Site and Services and process the information on our behalf and under our instructions, as well as with our business partners and affiliates who may offer you products and services, based on your preferences (if we have a legitimate interest in doing so or if you have indicated your desire to receive these, as applicable).
- International Transfer. We may use service providers and/or subcontractors and/or cooperate with or have business partners and affiliates located in countries other than your own, and send them your Personal Information. We will ensure to have agreements in place with such parties ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
- Your Rights. Subject to applicable law and additional rights as set forth below, you may have a right to access, update and/or delete your Personal Information and obtain a copy of the Personal Information we have collected about you. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. You also have the right to object at any time to processing your personal data for marketing purposes.
- Retention. We retain information for as long as necessary for the purposes set forth in this Privacy Notice.
- Security. We implement industry standard measures aimed at reducing the risks of damage and unauthorized access or use of Personal Information, but they do not provide absolute information security.
- Changes to the Privacy Notice. We may change this Privacy Notice from time and shall make notice of such changes.
Information We Collect
We collect information from you when you choose to use our Site and/or Services. In order to register a product and/or receive related Services and/or make a purchase through the Site, you will be required to provide us with certain Personal Information. We also collect Personal Information when you make use of the Site, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason.
Examples of the Personal Information that we collect from you may include your name, email address, phone number, postal address, and credit card details. Such Personal Information may be collected by us through the Site.
In addition, when you use the Site, certain information may be automatically gathered about your computer or mobile device, such as operating system, IP address, device ID, and subject to your consent as may be required under applicable law, (geo) location, as well as your browsing history and any information regarding your viewing and purchase history on our Site. It is your voluntary decision whether to provide us with any such Personal Information, but if you refuse to provide such information we may not be able to register your product and/or provide you with the Services.
How We Use Your Personal Information
We and any of our trusted third-party subcontractors and service providers may use the Personal Information we collect from and about you for any of the following purposes: (1) to provide you with the Site and/or Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with customized content, targeted offers, and advertising on the Site, on other third-party sites or apps you may visit, or via e-mail; (5) to contact you with informational newsletters and promotional materials relating to our Site and Services and with miscellaneous updates regarding our product; (6) to review the usage and operations of our Site and Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Site and Services, and address any problems with the Site and/or Services and (9) to provide customer support.
By analyzing all information we receive, including all information concerning users, we may compile statistical information across a variety of platforms and users (“Statistical Information”). Statistical Information helps understand trends and customer-needs so that new products and services can be considered and so existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Information. We may share such Statistical Information with our partners without restriction, on commercial terms that we can determine in our sole discretion.
We may use your Personal Information as required or permitted by any applicable law.
Basis for Processing Your Personal Data
Processing your Personal Information is necessary for the provision of the Site and Services to you, including responding to your inquiries or requests, contacting and communicating with you and providing customer support.
Processing your Personal Information for third-party marketing purposes is based upon your consent. When visiting the Site, you shall be asked to accept the terms of this Privacy Notice, including the processing of your Personal Information for marketing purposes. You may withdraw your consent to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes at any time by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
Processing for the purposes of developing and enhancing our products and services, for analytics and usage analysis, for the marketing of our products and services, for fraud prevention and security and for our recordkeeping and protection of our legal rights – are all necessary for the purposes of legitimate interests that we pursue.
Disclosure of Information
We may share your information, including Personal Information, as follows:
Business Partners, Service Providers, Affiliates, and Subcontractors
We may disclose information, including Personal Information we collect from and/or about you, to our trusted service providers, business partners, affiliates, subcontractors, who may use such information to: (1) help us provide you with the Site and/or Services; (2) aid in their understanding of how users are using our Site and Services; (3) provide to you targeted offers and advertising on our Site and on other sites you choose to visit, subject to your consent as may be required under applicable law.
We may use subcontractors and service providers and have business partners and affiliates who are located in countries other than your own and send them information we receive (including Personal Information). We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice. You hereby consent to such international transfer.
We may transfer our databases containing your Personal Information if we sell our business or part of it, including in cases of liquidation. Information about our users, including Personal Information, may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition and shall continue being subject to the provisions of this Privacy Notice.
Law Enforcement Related Disclosure
We will fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity, behavior or (digital) content and information of or related to an individual, including in the event of any user suspected to have engaged in illegal or infringing behavior. We may also share your Personal Information with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our rights, property or safety (including the enforcement of this Privacy Notice); (ii) to protect the rights, property or safety of third parties; (iii) when required by law, regulation, subpoena, court order or other law enforcement related issues; or (iv) as is necessary to comply with any legal and/or regulatory obligation. You can request such Personal Information as specified herein by emailing us at SUPPORT EMAIL ADDRESS.
Other Uses or Transfer of Your Information
We allow you to use our Site and Services in connection with third-party services, sites, and/or mobile applications. If you use our Site and/or Services with or through such third-parties, we may receive information (including Personal Information) about you from those third parties. Please note that when you use third-parties outside of our Site and/or Services, their own terms and privacy policies will govern your use of those services.
How We Protect Information
We make efforts to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
If you have not disabled third party cookies (please see section on Cookies below), and you use our Site or Services, additional third parties may also be serving as controllers in connection with the collection of your Personal Data. You can read more about third party cookies below.
How to Access and Limit Our Use of Certain Information
You have certain rights in relation to the Personal Information that we or our co-controllers hold about you, as detailed below. For any requests to exercise such rights with respect to information held by our co-controllers, please contact the applicable co-controller directly at the information provided. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
- Right of Access and Data Portability. You have a right to know what Personal Information we collect about you and, in some cases, to have the information communicated to you. Subject to the limitations in applicable law, you may be entitled to obtain from us a copy of the Personal Information you provided to us (excluding information that we obtained from other sources) in a structured, commonly-used, and machine-readable format, and you may have the right to (request that we) transmit such Personal Information to another party. If you wish to exercise this right please contact us letting us know what information in particular you would like to receive and/or transmit. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, for instance, if the information includes Personal Information about another person. Where we are not able to provide you with information that you have asked for, we will endeavor to explain to you why. We will try to respond to any request for a right of access as soon as possible.
- Right to Correct Personal Information. Subject to the limitations in applicable law, you may request that we update, correct or delete inaccurate or outdated Personal Information and/or that we suspend the use of Personal Information, the accuracy of which you may contest, while we verify the status of that Personal Information. We will correct your Personal Information within a reasonable time from the receipt of your written request thereof.
- Deletion of Personal Information. In certain circumstances you have a right to have Personal Information that we hold about you deleted. Should you wish to have any Personal Information about you deleted, please contact us using the contact information specified in this Privacy Notice. Subject to applicable law, we will delete Personal Information provided to us by a user within a reasonable time from the receipt of a written (including via email) request by such user to delete such collected Personal Information. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Information, you should clear our cookies from any device where you have used our Services. We may retain certain Personal Information (including following your request to delete) for audit and record-keeping purposes, as well as other purposes, all as permissible and/or required under applicable law. We may also retain your information in an anonymized form.
- Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Information processed for direct marketing purposes. If you do, please notify us by contacting us as detailed in this Privacy Notice. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
- Right to Object. Subject to applicable law, you may have the right to object to processing of your Personal Information including for the purpose of direct marketing.
- Supervisory Authority. If you are a European Citizen, you may have the right to submit a complaint to the relevant supervisory data protection authority.
Subject to applicable law, we retain information as necessary for the purposes set forth above. We may delete information from our systems, without notice to you, once we deem it is no longer necessary for the purposes set forth in this Privacy Notice.
Cookies and Similar Technologies
What are Cookies?
A cookie is a small piece of text that is sent to a user’s browser or device. The browser provides this piece of text to the device of the originating user when this visitor returns.
- A “session cookie” is temporary and will remain on your device until you leave the Site.
- A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device for much longer or until you delete it.
- First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
- Information may also be collected through web beacons, which are small graphic images (“pixel tags”), which usually work together with cookies in order to identify users and user behavior. These may be shared with third parties.
We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above.
The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories (the type of cookie and why we use it):
- Necessary. These cookies are necessary in order to allow the Site to work correctly. They enable you to access the Site, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.
- Functionality. These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.
- Security. These cookies can help us identify and prevent security risks. They may be used to store your session information.
- Performance. These cookies can help us collect information to help us understand how you use our Site, such as whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Site.
- Analytics. These cookies help us learn more about which features are popular with our users and how our Site can be improved.
- Advertising. These cookies are placed in order to delivery content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites.
How to Adjust Your Preferences
Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may function improperly when cookies are disabled or removed.
For your convenience, below are links to instructions on how to change your cookie settings in several popular internet browsers:
- Chrome Desktop: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
- Chrome Android: https://support.google.com/chrome/answer/95647
- Firefox Desktop: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- Firefox Android: https://support.mozilla.org/en-US/kb/enable-or-disable-cookies-firefox-android
- Safari Desktop: https://support.apple.com/kb/ph21411
- Safari iOS: https://support.apple.com/ht201265
By changing your device settings, you can prevent your device’s ad identifier being used for interest-based advertising, or you can reset your device’s ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device’s settings, although settings may vary from device to device.
Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements, it only means the advertisement you do see will be less relevant to your interests.
Third Party Cookies
- Google AdWords remarketing service is provided by Google Inc.
- You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
- Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
- For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
- Twitter remarketing service is provided by Twitter Inc.
- You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
- Facebook remarketing service is provided by Facebook Inc.
- You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
- To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/about/ads/#568137493302217
- Facebook adheres the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
- For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
- Pinterest remarketing service is provided by Pinterest Inc.
- You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
Third-Party Applications and Services
All use of third-party applications or services is at your own risk and subject to such third party’s privacy policies.
Displaying Content From External Platforms
These services allow you to view content hosted on external platforms directly from the pages of this Application and interact with them. If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.
Interaction With External Social Networks And Platforms
These services allow interaction with social networks or other external platforms directly from the pages of this Application.
- The interaction and information obtained by this Application are always subject to the User’s privacy settings for each social network.
- If a service enabling interaction with social networks is installed it may still collect traffic data for the pages where the service is installed, even when Users do not use it.
Twitter Tweet Button and Social Widgets (Twitter)
- The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter Inc.
- Personal Data collected: Cookie and Usage Data.
Facebook Like Button and Social Widgets (Facebook)
- The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
- Personal Data collected: Cookie and Usage Data.
Managing Email Addresses And Sending Communications
Subject to your consent and applicable law, we may send you e-mail or other messages and/or a newsletter about us or our Services. You may remove your Personal Information from our mailing list and stop receiving future communication from us by following the UNSUBSCRIBE link located at the bottom of each communication or by emailing us at SUPPORT EMAIL. You will also be given the opportunity to unsubscribe from commercial messages in any such e-mail or message we send. Please note that we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them.
We may use third party services that make it possible to manage a database of subscription based email contacts to communicate with the User via email. The services are used to collect data concerning the date and time when the mail is viewed by the User, as well as when the User interacts with incoming mail, such as by clicking on the links included in the email.
- MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC d/b/a MailChimp, a State of Georgia limited liability company.
- Personal Data collected: Email address.
- Klaviyo is an email address management and message sending service provided by Klaviyo, Inc, a State of Massachusetts company.
- Personal Data collected: Email address.
- Hubspot is an email address management and message sending service provided by Hubspot, Inc, a State of Massachusetts company.
- Personal Data collected: Email address.
We do not knowingly collect personally-identifiable information from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
If you are a California Resident, under California Law you have the Right to
- Request Deletion of any personal information about you that we have collected from you (there may be exceptions; including but not limited to employment and contractual relationships).
- Request that we inform you of the sale of your personal information (we do not sell your personal information) or the transfer of your personal information for a business purpose.
- Request disclosure regarding the collection of your personal information.
- Not to face discrimination for exercising your rights under the CCPA.
If you choose to exercise your rights under this regulation, please use the above link or via the contact information provided on the Privacy page.
When visiting this Site, you shall be asked to accept the terms of this Privacy Notice. If you do not agree with the terms hereof, please do not use the Site. We may update this Privacy Notice from time to time in which case, we shall notify you of such changes. We will post the updated Privacy Notice on this page. Please come back to this page every now and then to make sure you are familiar with the latest version. Any new Privacy Notice will be effective from the date it is accepted by you.
Comments and Questions
Data Controller And Owner
Copyright © 2021 [XYZ COMPANY]. All rights reserved.
Updated by [XYZ COMPANY], on [DATE].