LAST UPDATED: JUNE 18, 2018
Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data
controller of your personal data is PrivCo Holding, Inc. of 149 East 23rd Street, #1904, New York, NY 10010.
Must Read Sections: We draw your attention in particular to the sections entitled “International Data Transfer“and “Your Rights.”
Changes to this Policy: We will post any modi cations or changes to the Policy on our Site/Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email and/or post a notice on our Site/Services prior to such changes(s) taking effect.
1. Purposes of Processing
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as de ned in the UK Data Protection Act 1998/the European Data Protection Directive 95/46/EC/General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identi es you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Site/Services. If you registered with us, you will have been asked to click to agree to provide this information in order to access our services, purchase our products, view our content. This consent provides us with the legal basis we require under applicable law to process your data. If you do not agree to our use of your personal data in line with this Policy, please do not use our Site/Services.
2. Collecting Your Personal Data
We collect information about you in the following ways:
Information You Give Us. This includes:
the personal data you provide when you register to use our Site/Services, including your name, email address, and password; the personal data you provide when you report a problem with our Site/Services or when we provide you with customer support; the personal data you provide when you correspond with us by phone, email or otherwise.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site/Extension/Services. For example, when visiting our Site/Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site/Services, pages you viewed, crash reports, how long you spent on a page, access times and information about your use of and actions on our Site/Services. Our Extension also collects information related to the websites you view in order to provide you with data and information that matches your searches and queries on the Services. We collect this information about you using cookies. Please refer to the sections on cookies, below.
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
What are cookies?
We may collect information using “cookies.” Cookies are small data les stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site/Services.
We use two broad categories of cookies: (1) rst party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site/Services; and (2) third party cookies, which are served by service providers on our Site/Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
our Site/Services uses the following types of cookies for the purposes set out below:
These cookies are essential to provide you with services available through our Site/Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site/Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site/Services to remember choices you make when you use our Site/Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site/Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site/Services.
These cookies are used to collect information about traffic to our Site/Services and how users use our Site/Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Site/Services, the websites that referred them to our Site/Services, the pages they visited on our Site/Services, what time of day they visited our Site/Services, whether they have visited our Site/Services before, and other similar information We use this information to help operate our Site/Services more e#ciently, to gather broad demographic information and to monitor the level of activity on our Site/Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site/Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Site/Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
You can typically remove or reject cookies via your browser settings. In order to do this,
follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on
your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site/Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site/Services.
4. PIXEL TAGS
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site/Services to track the actions of users on our Site/Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Site/Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our personal data.
5. DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
6. Using Your Personal Data
We may use your personal data as follows: to operate, maintain, and improve our Site/Services, products, and services; to manage your account, including to communicate with you regarding your account, if you have an account on our Site/Services; to operate and administer our rewards program and other promotions you participate in on our Site/Services; to respond to your comments and questions and to provide customer service; to send information including technical notices, updates, security alerts, and support and administrative messages; with your consent, to send you marketing emails about upcoming promotions, and other news, including information about products and services o ered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you; as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and as described in the “Sharing of your Personal Data” section below.
7. Sharing Your Personal Data
We may share your personal data as follows:
Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
Affiliates. We may share some or all of your personal data with our a liates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our a liates where you wish to receive marketing communications from them.
Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, nancing, acquisition, or bankruptcy transaction or proceeding.
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
8. Anonymous Data
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identi able to you. We use this anonymous data to analyse usage patterns in order to make improvements to our Site/Services.
9. User Generated Content
If you provide feedback to us, we may use and disclose such feedback on our Site/Services.
10. International Data Transfer
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site/Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance
with this Policy.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 20 below.
We will only retain your personal data as long reasonably required for you to use the Site and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes).
13. Our Policy on Children
Our Site/Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in Section 20 below. We will delete such information from our les as soon as reasonably practicable.
14. Sensitive Personal Data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site/Services or otherwise to us.
15. Your Rights
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) any new processing of your personal data that we may carry out beyond the original purpose; or (iii) the transfer of your personal data outside the EEA. Please note that your use of some of the Site/Services may be ineffective upon opt-out.
Access. You may access the information we hold about you at any time via your account or by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your personal data.
Move. Your personal data is portable, i.e. you have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in Section 17 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: email@example.com. We will reply to your complaint as soon as we can and in any event, within 45 days.
17. Contact Information
We welcome your comments or questions about this Policy. You may contact us in writing at firstname.lastname@example.org.