Privacy Policy

Introduction

Grounds for Data Collection

The processing of your personal information (i.e., all information that can potentially allow your identification by reasonable means; hereinafter referred to as “Personal Information“) [add explanation of legal grounds for processing personal information, such as:] is necessary for the performance of our contractual obligations to you, as well as to provide our services, to protect our legitimate interests, and to comply with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure, and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to read the Privacy Policy and use it to make informed decisions.

What Information Do We Collect?

We collect two types of data and information from Users.

The first type of information is unidentified and non-identifiable information pertaining to a User that may be made available or collected through use of the Site (“Non-Personal Information“). We are not aware of the identity of a User from whom Non-Personal Information has been collected. Non-Personal Information being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g., browser type and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information about your activity on the site (e.g., pages viewed, online browsing, clicks, actions, etc.).

The second type of information is Personal Information, which is individually identifiable information, that is, information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device Information: We collect personal information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), and other information relating to your activity through the Site.
[add types of personal information collected and respective explanations, such as:]
Registration Information: When you register on our Site, you will be asked to provide us with certain data, such as: full name; email or physical address and other information.

How May We Receive Information About You?

What Information Do We Collect?

We do not rent, sell, or share user information with third parties except as described in this Privacy Policy.

We may use the information for the following:

[add types of use in detail, such as:]
To communicate with you – sending notices regarding our services, providing technical information, and responding to any customer issues you may have;
To communicate with you and keep you informed of our latest updates and services;
To serve you with advertisements when you use our Site (see more under “Advertising”);
To market our sites and products (see more under “Marketing”);
For statistical and analytical purposes with the intent of improving the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliates, and subcontractors.

In addition to the purposes mentioned in this Privacy Policy, we may share personal information with our trusted third-party providers, who may be located in different jurisdictions around the world, for any of the following purposes:

Hosting and operating our Site;
[add and modify relevant types of third parties, such as:]
Providing our services to you, including providing a personalized display of our Site;
Storing and processing such information;
Serving you with advertisements and helping us evaluate the success of our advertising campaigns, as well as retargeting some of our users;
Providing you with marketing offers and promotional materials relating to our Site and services;
Conducting research, technical diagnostics, or analytics;

We may also disclose information if we believe in good faith that disclosure of such information would be useful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, or security issues; (iv) establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property, or safety of ourselves, our users, your own safety, or that of third parties; or (vi) for the purpose of collaborating with law enforcement authorities and/or if we deem it necessary to enforce intellectual property or other legal rights.

User Rights

You may request to:

Receive confirmation of whether or not non-personal information about you is or is not being processed and access your stored personal information, together with supplementary information.
Receive a copy of the personal information that you voluntarily and directly provided to us in a commonly used, structured, machine-readable format.
Request rectification of your personal information that is under our control.
Request deletion of your personal information.
Object to the processing of your personal information by us.
Request restriction on the processing of your personal information by us.
Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the above-mentioned rights or wish to receive more information, please contact our Data Protection Office (“DPO”) using the details provided below:

[add contact details].

Retention

We will retain your Personal Information for as long as necessary to provide our services and as needed to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purpose for such collection, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will maintain records containing customer personal data, account opening documents, communications, and anything in compliance with applicable laws and regulations.

We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A cookie is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very useful and can be used for various different purposes. Such purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and making the interaction between you and our services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our services.

The Site uses the following types of cookies:

. “session cookies” which are stored only temporarily during a browsing session to allow normal use of the system and are deleted from your device when the browser is closed;

b. “persistent cookies”, which are read only by the Site, saved on your computer for a fixed period, and are not deleted when the browser is closed. These cookies are used when we need to know who you are for repeat visits, for example, to allow us to store your preferences for a future visit;

c. “third-party cookies”, which are set by other online services that run the content on the page you are viewing, for example, third-party analytics companies that monitor and analyze our web access.

Cookies do not contain information that personally identifies you, but personal information that we store about you may be linked by us to information stored in and obtained from cookies. You may remove cookies by following the instructions in your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do, etc. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit the sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third-Party Information Collection

Our policy addresses only the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties or sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each party to which you choose to disclose information.

This Privacy Policy does not apply to the practices of companies we do not own or control, or to individuals we do not employ or manage, including third parties to whom we may disclose information as set forth in this Privacy Policy.

We take great care in implementing and maintaining the security of the Site and your information. [explain your security practices, such as: we employ industry-standard procedures and policies to ensure the security of the information we collect and retain, prevent unauthorized use of any information, and require any third parties to comply with similar security requirements, in accordance with this Privacy Policy]. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express or implied, that we will prevent such access.

Data Transfer Outside the EEA

Advertising

We may use third-party advertising technology to serve advertisements when you access the Site. Such technology uses your information regarding your use of the services to serve you with advertisements (e.g., by inserting third-party cookies into your Internet browser).

[Add information about opt-out options for personalized advertising, such as:] You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, as well as your choices regarding having this information used by these companies, including how to opt out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your Personal Information, such as name, email address, telephone number, etc., ourselves or using our third-party subcontractors for the purpose of providing you with promotional materials concerning our services, which we believe may be of interest to you.

Out of respect for your right to privacy, we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving our marketing emails, we may send other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate Transactions

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site has not been designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [Add applicable email address].

Updates or Changes to This Privacy Policy

How to Contact Us