1.2 Data Controller
2. INFORMATION WE COLLECT
There are different categories of information we collect.
2.1 Information you give to us
We collect personal information that you voluntarily provide to us such as name, company name, address, and contact information like phone number and/or email.
2.2. Information automatically collected
2.3. Children’s data
Our website and services are not directed to children under 18 and we do not knowingly collect any personal information directly from children under 18. If you do believe that we are processing the personal information pertaining to a child inappropriately, we take this very seriously and urge you to contact us at email@example.com.
3. HOW WE USE THE INFORMATION WE COLLECT
We use personal information collected via our Services to protect our Services, to respond to user inquiries, and/or offer support to users and for other business purposes as specified 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 and/or contractual obligations. We indicate the specific grounds we rely on next to each purpose listed below:
3.1 To protect our Services
We may use your personal information as part of our efforts to keep our Services safe and secure (for example, for fraud and/or hacking monitoring and prevention).
3.2 To respond to user inquiries and/or offer support to users
We may use your personal information to respond to your inquiries via email or our contact form and to solve any potential issues you might have with the use of our Services.
3.3 For other business purposes
We may use your personal information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our website, and to evaluate and improve our Services, website, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
4. SHARING & DISCLOSURE
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 your personal information if you have given us specific consent to use your personal information for a specific purpose.
4.2 Legitimate Interests
We may process your personal information when it is reasonably necessary to achieve our legitimate business interests.
4.3 Performance of a contract
Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. Our contracts will specify the purposes of how we may use your personal information.
4.4 Legal obligations
We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
4.5 Vital interests
We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, and illegal activities, or as evidence in litigation in which we are involved.
5. COOKIES AND OTHER TRACKING TECHNOLOGIES
5.1 Why We Use These Technologies
We use these technologies for a number of purposes, such as:
- • To enable you to use and access our website.
- • To enable, facilitate and streamline the functioning of and your access to our website.
- • To better understand how you navigate through and interact with our website and to improve it.
- • To monitor and analyze the performance, operation, and effectiveness of our website.
- • To enforce legal agreements that govern the use of our website.
- • For fraud detection and prevention, trust and safety, and investigations.
- • For purposes of our customer support, analytics, research, product development, and regulatory compliance.
When you visit our websites we place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and can enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different so visit the “help” section of your browser when to learn about cookie preferences and other privacy settings that may be available. Please note that if you choose to remove or reject cookies or clear local storage this could affect the features, availability, and functionality of our websites.
5.3 Flash Cookies
We may use Flash Cookies, also known as Local Stored Objects, and similar technologies to personalize and enhance your online experience. A Flash cookie is a small data file placed on a computer using Adobe Flash technology. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use Flash cookies to personalize and enhance your online experience and to deliver content for Flash players. We may also use Flash cookies for security purposes, to gather certain website metrics, and to help remember settings and preferences. Flash cookies are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please visit Adobe’s website. If you disable Flash cookies or other similar technologies, please note that you may not have access to certain content and product features.
5.4 Pixel Tags and Web Beacons
Pixel tags and web beacons are tiny graphic images and small blocks of code placed on website pages, ads, or in our emails that allow us to determine whether you performed a specific action. When you access these pages the pixel tags and web beacons let us know you have accessed the web page. These tools help us measure response to our communications and improve our web pages.
5.5 Server Logs and Other Technologies
We collect many different types of information from server logs and other technologies. For example, we collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices require to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our website and the website you visit after you leave our site. These tools help us improve user experience and deliver our services.
5.6 Third Parties
We may also allow certain business partners to place these technologies on our website. These partners use these technologies to (1) help us analyze how you use our website, such as by noting the third party services from which you arrived, (2) help us detect or prevent fraud or conduct risk assessment. For example, to help us better understand how people use our website, we work with Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser by clicking here: https://tools.google.com/dlpage/gaoptout. You can find more information about how Google uses your information here: https://policies.google.com/privacy?hl=en-US
5.7 Third Party Social Plugins
Our website may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of our website. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with our website to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.
5.8 Your Choices
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. Your mobile device may allow you to control cookies through its settings function. Refer to your device manufacturer’s instructions for more information. If you choose to decline cookies, some parts of our website may not work as intended or may not work at all.
6. OPERATING GLOBALLY & INTERNATIONAL TRANSFERS
7. ERASURE AND SECURITY
8. YOUR RIGHTS
8.1 European Economic Area residents
In the European Economic Area, you have certain rights under applicable data protection laws.
European Economic Area residents have the following rights according to the GDPR:
I – The right to be informed
II – The right of access
III – The right to rectification
IV – The right to erasure
V – The right to restrict processing
VI – The right to data portability
VII – The right to object
VIII – Rights in relation to automated decision making and profiling.
To make such a request, please contact us at firstname.lastname@example.org. We will consider and act upon any request in accordance with applicable data protection laws. You have the right to withdraw your consent at any time. This will not however affect the lawfulness of the processing before its withdrawal. If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
8.2 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 reject cookies. If you choose to remove cookies or reject them, this could affect certain features of our website.
8.3 California residents
California Civil Code Section 1798.83 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 contact us at email@example.com.
California Residents have the following rights under the CCPA:
I – The right to know what personal information a business collects and how it is used and shared;
II -The right to delete personal information;
III – The right to opt-out of the sale of personal information; and
IV – The right to non-discrimination for exercising the CCPA rights.
We do not sell personal information of California residents or any other users.
8.4 Brazilian residents
Brazilian residents have the right according to Art. 18 LGPD to obtain from the data controller, in relation to their data processed by the data controller, at any time and upon request:
I – confirmation of the existence of processing;
II – access to data;
III – correction of incomplete, inaccurate, or outdated data;
IV – anonymization, blocking, or deletion of unnecessary, excessive, or processed data in violation of the provisions of the LGPD;
V – portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, subject to commercial and industrial secrets;
VI – deletion of personal data processed with the consent of the data subject, except in the cases provided for in Art. 16 of the LGPD;
VII – information on public and private entities with which the controller made shared use of data;
VIII – information about the possibility of not giving consent and about the consequences of the refusal;
IX – revocation of consent
If you are a Brazilian resident and would like to make such a request, please contact us at firstname.lastname@example.org.
9. DATA PROTECTION OFFICER
We have appointed Florian Sommerfeld as our data protection officer. If you have questions or comments about this policy, you may email him at email@example.com.
11. CONTACT US
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org.
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