Updated April 2022
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
Please note that this Policy does not apply to information collected through third-party websites or services that you may access through the Services or that you submit to us through email, text message or another electronic message or offline.
If you are visiting the Sites from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data.
WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give Us.
Information we collect from you may include:
Information Automatically Collected. We may automatically record certain information about how you use our Sites (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Sites are used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.
We also may use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics use of your personal data here: https://www.google.com/analytics/terms/us.html.
USE OF PERSONAL INFORMATION
To provide our service
We will use your personal information in the following ways:
To comply with the law
We use your personal information as we believe necessary or appropriate to comply with applicable laws (including anti-money laundering (AML) laws and know-your-customer (KYC) requirements), lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities.
To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
For compliance, fraud prevention, and safety
We may use your personal information to protect, investigate, and deter fraudulent, unauthorized, or illegal activity.
SHARING OF PERSONAL INFORMATION
In Short: We only share information with the following categories of third parties.
We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details.
The Company has offices outside of the EU and has affiliates and service providers in the United States and in other countries. Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
EU users should read the important information provided below about the transfer of personal information outside of the European Economic Area (EEA).
HOW INFORMATION IS SECURED
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
We employ industry-standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.
HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user’s account.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
INFORMATION CHOICES AND CHANGES
Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services, and review, correct, or delete it by sending a request to [email protected] You can request to change contact choices, opt-out of our sharing with others, and update your personal information and preferences.
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. For more information, please see our Cookies Policy.
CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you may contact us at: [email protected]
If you are under the age of majority in your jurisdiction of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children’s Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Sites and subsequently we will delete that information.
NOTICE TO EU DATA SUBJECTS
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at [email protected]
|Processing Purpose||Legal Basis|
|To provide our service||Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Service.|
|To communicate with you||These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To optimize our platform|
|For compliance, fraud prevention, and safety|
|To provide our service|
|To comply with law||We use your personal information to comply with applicable laws and our legal obligations.|
|With your consent||Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected]|
Use for New Purposes
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email to [email protected] We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why we are subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or respond to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here. ( https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm)
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
If you are located in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. With that in mind, we use appropriate safeguards when we transfer your information outside the EEA or UK to ensure your personal information remains protected and to comply with applicable data protection laws.
The bases, mechanisms, and measures we rely on include:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt out, you may:
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.