[Last Modified: July 31, 2023]
(i) The EU General Data Protection Regulation ("GDPR"), which shall apply to you in the event you are a resident of the European Economic Area ("EEA"); and
(ii) The California Consumer Privacy Act of 2018 ("CCPA") which shall apply to you in the event you are a "California resident", as defined under the CCPA.
THE INFORMATION WE COLLECT AND PURPOSE OF USE
We collect non-identifiable aggregated information ( "Non-Personal Data") about your device and your use of Services. In addition, we collect data that identifies a user or may identify a user, which is classified as "Personal Data" under applicable law. All, as detailed below.
EU General Data Protection Regulation ("GDPR") & Lawful Basis for Data Processing
Depending on the nature of your interaction with the Offer, our lawful basis for collection of Personal Data, as required under the GDPR, is as follows:
(i) We process certain Online Identifiers (as described below) during your download and use of the Service and for functionality and operational purposes, which we have a legitimate interest in processing;
(iii) We may process information provided by you voluntarily - meaning, if and when you choose to provide us with information such as through contact us communications in order to perform our contract with you.
The types of data that we collect as well as the purpose for processing such data are specified below:
DATA WE COLLECT
1. Technical Data and Online Identifiers:
If you use our offer Services, we will collect your IP addresses.
In addition, we will collect technical data transmitted from your device such as, your aggregated use of the Service, statistics, type of browser, operating system type, language and the time and date you access and use the Service, website which you lead you to the Offer, approximate geographical location and Internet Service Provider (ISP)
Purpose of collection and use-
Collection of the IP address is necessary for operating and providing the Service, to further improve, refine, customize and develop those Services and Offer, as well as to perform research, and conduct associated analytical and statistical activities, detect fraud, security or technical issues in connection with the Services and calculate payments.
Note that, in some jurisdictions Online Identifiers, might be considered as Non-Personal Data, and we treat such data in compliance with applicable laws.
2. Contact Details:
If you contact us for support and voluntarily provide us with your contact information, including your name and email address.
Purpose of collection and use-
We will process your contact details and contact history with us only in order to respond to you, provide you with support, assist you or provide you with any other service that you may request.
We will retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of future claim, to provide you with support, or to improve our services).
California Consumer Privacy Act 2018 ("CCPA") & Categories of Personal Information Collected and Shared
Under the CCPA Personal Information does not include: Publicly available information from government records; Deidentified or aggregated consumer information.
As required under the CCPA , please see below a table specifying the categories of Personal Information we collect:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Disclosures of Personal Information for a business purpose:
In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose: (A) Identifiers;
We disclose your Personal Information for a business purpose to the following categories of third parties: service providers & data aggregators (e.g. for analytics purposes), business partners (for fraud detection and payment calculation, as well as feed providers).
Sale of Personal Information
In the preceding twelve (12) months, Company has not sold Personal Information.
HOW WE COLLECT DATA
Depending on the nature of your interaction with the Services and Offer, the above detailed data is collected as follows:
- In the event you voluntarily choose to provide us with information, e.g., when you contact us.
- We will ask for your consent to collect Personal Information and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law.
SHARING DATA WITH THIRD PARTIES
We do not share your Personal Data with any third parties. However, we may disclose such information if we have a good faith belief that the disclosure is reasonably necessary in order to: (i) comply with applicable law, regulation or governmental request and collaborate with law enforcement; (ii) enforce our policies and agreements, and establish or exercise our rights to defend against legal claims; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) prevent harm to the rights, property or safety of us, our users, yourself or any third party; (and (v) enforce intellectual property or other legal rights.
We will also share Online Identifiers in order to calculate our business partner's payments and to detect fraud;
Furthermore, we may disclose your Personal Data to a third party for a "Business Purpose" (as defined under the CCPA). When we disclose Personal Data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except performing the contract. We reserve the right to use, disclose or transfer (for business purposes or otherwise) aggregated and processed Non Personal Data to third parties, including, inter alia, affiliates, for various purposes including commercial use. This information may be collected, processed and analyzed by us and transferred in a combined, collectively and aggregated manner (i.e., your information is immediately aggregated with other users) to third parties.
In Addition, information with respect to Google's use of the data from our use of Google Analytics Cookies, is available in Google's policies located at: www.google.com/policies/privacy/partners . We also recommend you to read about Google Analytics' currently available opt-outs available at: https://tools.google.com/dlpage/gaoptout/ .
Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited. For more information about your controls in this regard, you may review the following links:
THIRD PARTY CONTENT
You may remove the Offer and reset your device settings at any time.
Depending on applicable data privacy and related laws in your jurisdiction, you may have certain rights in respect of your Personal Data, including the right to access your Personal Data, request to delete, correct or amend it.
For more information regarding you rights please review our Privacy Rights Overview
DATA RETENTION AND SECURITY
We retain the information we collect solely for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain the information we collect for longer periods, for example, when we are required to do so in accordance with legal or tax requirements, or if we reasonably believe, at our discretion, that we need to obtain an accurate record of your correspondence or any dealing with us, for example, in the event of any complaints. We use high security techniques to prevent your information from being accessed, used or disclosed without authorization, unlawfully destructed or accidental loss. However, although we make best efforts we can't provide 100% security and we cannot be held responsible for unauthorized or unintended access that is beyond our control. If you believe that your privacy was treated not in accordance with the provisions herein, or you have reasonable concern with that any person attempted to abuse our Service, please contact us firstname.lastname@example.org.
DO NOT TRACK DISCLOSURE
The Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see http://www.allaboutdnt.com/ .
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