Last modified: October 31, 2022
Throughout this Policy we use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland. If you reside in the Designated Countries, you have a number of important rights we want you to be aware of pursuant to the European General Data Protection Regulation (the “GDPR”). These rights will be indicated by reference to the Designated Countries where applicable.
Sources of information
This Policy applies to information we collect:
This Policy does not apply to information collected by:
What information we collect
We collect information to provide better services to all our users––from remembering user preferences to contacting you regarding services or opportunities that may be of interest to you. The information we collect, and how that information is used, depends on how you use our services.
We may collect and process some or all of the following types of information from you:
The provision of your full name, e-mail address, and IP address are required from you if you choose to create an account on our Websites and Mobile Apps. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
We may use the information that we collect in a variety of ways in providing our service, including:
We may occasionally contact you through email, phone, and/or notices posted on our Websites and Mobile Apps. We may send you messages about the availability of our services, security, or other service-related issues. We may also send messages about how to use the services, network updates, and promotional messages from us. You may contact us at any time using our Contact Information below to change your communication preferences. Please be aware that you cannot opt-out of receiving certain service messages from us, including security and legal notices.
You have choices about our use of your information. At any time, you can withdraw consent you have provided by contacting us using our Contact Information below.
We will only collect and process your information where we have lawful bases to do so. Lawful bases include but are not limited to consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the services you have requested)) and legitimate interests.
If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us using the Contact Information provided below.
We do not share your personal data with advertisers, other companies, or individuals, except in the following cases:
We may need to share your information when we believe it’s required by law or to help protect the rights and safety of you, us, or others. It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of the Company, our users, personnel, or others. We attempt to notify you about legal demands for your personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
For external processing
Merger, acquisition, or sale of assets
We take industry-standard security measures to ensure that all of your personal data is kept secure, including security measures to prevent personal data from being accidentally lost, used, or accessed in an unauthorized way, for the duration of your use of our services. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Websites and Mobile Apps, therefore any transmission remains at your own risk. Once we have received your information, we will use strict procedures and security features in order to prevent unauthorized access.
Cross-Border Data Transfers
We may store and use your data outside your country. We may process data both inside and outside of the United States and will rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country. In many cases, we will use European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the Designated Countries. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of your data. These clauses are designed to help safeguard your privacy rights and give you remedies in the unlikely event of the misuse of your personal data.
Keeping your information up to date
If your personal information details change, you may contact us to request an update or correction using our Contact Information below. We will endeavor to update your personal data information within thirty (30) days of any new or updated personal data being provided to us, in order to ensure that the information we hold about you is as accurate and up to date as possible.
Where we store your information
The information that we collect from you and process as a result of your use of the services may be transferred to, and stored at, a destination outside the Designated Countries. It may also be processed by our employees operating outside the Designated Countries who work for us. Such employees may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. By submitting your personal data and accessing this Websites and Mobile Apps, you agree to this transfer, storing or processing.
How long we keep your information
You can contact us any time using our Contact Information below to:
There are other ways to control the information we collect, including:
Browser settings: For example, you can configure your browser to indicate when we have set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. But remember that our services may rely on cookies to function properly, for things like remembering your user preferences.
Your GDPR rights
If you reside in the Designated Countries, you have a number of important rights we want you to be aware of. The rights available to you depend on our reason for processing your information.
If you would like to exercise any of these rights, please contact us using our Contact Information below. You may make any requests regarding these rights verbally or in writing. Upon receiving your request, we may request additional information so we are able to identify you and ensure you are the one making the request.
Notice to California Residents
If you are a California resident, California law may provide you with additional rights regarding our use of your personal data. For example, California's "Shine the Light" law (Civil Code Section 1798.83) permits users of our Websites and Mobile Apps that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, under California Civil Code Section 1789.3, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 N. Market Blvd., Suite S-202, Sacramento, California 95834, or by telephone at (800) 952-5210 in order to resolve a complaint or to receive further information. You may have additional rights under the California Consumer Privacy Act of 2018 (CCPA), such as the right to know what personal data is collected about you, the right to request that certain information be corrected or deleted, the right to opt out of the sale of your information (note, the Company does not sell your information), and the right not to be discriminated against. To make any requests pursuant to your California rights, please contact us in writing or by email using our Contact Information below.
We regularly review this Policy and make sure that we process your information in ways that comply with it. We hope that we can resolve any question or concern you raise about our use of your information.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
If you reside in the Designated Countries, you may lodge a complaint regarding the processing of your personal data with a supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.
We may collect information about your computer using Google Analytics, including but not limited to your IP address, operating system and browser information, and duration of session for purposes of system administration, customer support and to collect aggregate information for internal reporting purposes. We may also monitor a user’s sessions on our Websites and Mobile Apps to improve our features and identify bugs.
The cookies we use are "analytical" cookies. Some of the common uses for our cookies are as follows:
Everyprompt use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.