(Last modified: January 2, 2020)
Subject to applicable law, our lawful basis for processing Personal Data is as follows:
- We process certain Online Identifiers (as described below) during your use of our website and for functionality and operational purposes, which we have a legitimate interest in processing;
- In the event you contact us, we will process your contact details and other information you choose to provide us with in order to perform our contract with you.
If you have any questions about this Policy, please contact us email@example.com :
types of data we COLLECT
During your interaction with our website we may collect aggregated, non-personal non-identifiable information which may be made available or gathered via the users’ access to and use of the website (“Non-Personal Data“). We are not aware of the identity of the user from which the Non-Personal Data is collected. We may also collect from you during your access or interaction with the website individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data”). The types of data that we collect as well as the purpose for processing such data are specified in the table below.
|Type of Data||Purpose of Processing|
|Technical Data: We may collect technical Non-Personal Data from you. This information includes the type of device, operating system and browsers you use, the time and date you accessed the website, user’s actions (i.e., regarding its viewing and interaction with the website and Website Content, including visited web pages and clickstream), your approximate geographical location, any redirecting URLs.||We collect this information solely to operate, provide, maintain, protect, manage, customize and improve our website and the Website Content.|
|Contact Details: If you voluntarily contact us in any manner, or for any other request or notification, you may be required to provide us with certain information such as your name and email address which we will then process.||We will use your contact details only in order to respond to you, provide you with support, assist you or provide you with any other service that you request of us.|
|Online Identifiers: We may collect certain online identifiers such as your IP addresses.||We use Online Identifiers for: (i) our legitimate interests of operating, providing, maintaining, protecting, managing, and improving our website and the Website Content; (ii) enhancing your experience and optimizing the Website Content based on your preferences; (iii) performing research, as well as for analytical and statistical purposes; (iv) our legitimate interests of auditing and tracking usage statistics and traffic flow, auditing our affiliates, calculating payments, detecting fraud, security or technical issues in connection with the website; and (v) for advertising and optimization, purposes. The Online Identifiers might be collected by us or by our third-party affiliates, analytic, optimization partners and advertisers, whose cookies are placed in our website, as detailed in the “Cookies” section below.|
|Posting a Comment: If you voluntarily leave a comment on the website you will be asked to provide us with your name and email address. If we decide to post your comment, it will be posted under the name you provided, however we will not post your email address||We will use this information solely in order to upload your comment and for validation purposes.|
HOW WE COLLECT DATA
Depending on the nature of your interaction with the website, 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 Data and offer you the choice to opt-out of such collection if we are required to do so by any applicable law.
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. You may remove cookies by following the instructions in your device preferences (as detailed below). However, please note that if you choose to disable cookies, some features of the Website may not operate properly and your online experience may be limited.
Types of cookies used on our website:
There are several types of cookies that we use on our website as follows:
- These cookies are essential for enabling users’ navigation of the website, for the website to function properly, and for security purposes (e.g., prevent fraudulent use). This category of cookies either cannot be disabled, or if disabled, certain features of the website may not work.
- These cookies are used to collect information about how users use our website, in order to improve our services and the way we offer them, as well assess performance of the Website Content and the way it is displayed on our website.
Among others, we use the following third-party cookies on our website:
For additional information with regards to our use of Google products, click HERE.
You may easily opt-out of our website’s data collection, sharing process and targeted advertising services by following the instructions below:
- You may set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being used by us, by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more about how you can adjust your privacy and security settings. The following are some links which you may find helpful:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en;
- Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
- Safari: https://support.apple.com/kb/PH21411;
- You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page.
- As we explained above, we use third-party advertising companies to serve ads when you visit our website. These companies may collect certain information about you in order to provide advertisements about goods and services of interest to you. These third party advertisers may provide ways for you to opt out from or limit their collection of information from and about you. Please refer to these third party’s privacy policies to learn more. Please see: http://www.networkadvertising.org/managing/opt_out.asp for more information.
Note that once you opt out, part of the services provided by us might no longer be available and some features may not work if you revoke the data transfer. In addition, even if choose to you opt-out, you may still receive some content and advertising, however it will not be targeted content or advertising.
SHARING DATA WITH THIRD PARTIES
We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:
- Legal Requirement: We will share your information in this case, only as we are required to do so in order to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with a court injunction, comply with tax authorities, etc.);
- Policy Enforcement: We will share your information, solely to the extent needed to enforce our policies and agreements, in order to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;
- Website’s Rights: We will share your information in order to establish or exercise our rights to defend ourselves against legal claims when necessary, subject to applicable law;
- Third Party Rights: We will share your information, solely to the extent needed to prevent harm to the rights, property or safety of us, our users, yourself or any third party;
- Online Identifiers: We may share Online Identifiers in order to calculate our advertising partner’s payments and detect fraud.
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.
Data protection and privacy laws provide you with the following principal rights (among others) regarding your Personal Data, which you may exercise:
- The right to access your Personal Data;
- The right to ensure your Personal Data is accurate, complete and up to date;
- The right to have your Personal Data amended (by correcting, deleting or adding information);
- The right to object to processing of your Personal Data;
- The right to object to the processing of your Personal Data;
- The right to send or “port” your Personal Data;
- The right to file a complaint to a supervisory authority in your jurisdiction; and
- The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice;
- The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice.
Please review our Data Subject Rights Overview to learn more.
In the event that you contact us and request to exercise any of your rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate your data. Such process may take up to one (1) month, subject to applicable privacy law.
Please note that, you may have different rights then those which we listed above depending on and according to privacy protections laws in your jurisdiction.
If you wish to be provided with more information, you would like to exercise your rights, or in the event that you have any additional complaints about your privacy rights, please initially contact us at: firstname.lastname@example.org
If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available here , and send it to our privacy team at: email@example.com
Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.
We use physical, technical and administrative security measures for the services that we believe are in compliance with applicable laws and industry standards.
Our Website is not directed nor is it intended for use by children (a “child” meaning an individual that is under the age defined by applicable law which with respect to the EEA is under the age of 16 and under the age of 13 within the U.S.) and we do not knowingly process children’s information. We will discard any information that we receive from a user that is considered a “child” immediately upon us first becoming aware that such a user shared information with us. Please contact us at: firstname.lastname@example.org if you have reason to believe that a child has shared any information with us.
DO NOT TRACK DISCLOSURE
The Website does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.
- By sending an email to: email@example.com