Effective Date: March 01, 2023
We always seek to improve our Services to you, and that requires that we process information about you and your usage preferences. As we do so, we are absolutely committed to protecting your privacy and the security of your Data.
The term “Data” does not apply to information which does not relate to an identified or identifiable individual or to personal information or data rendered anonymous in such a manner that the individual is not or no longer identifiable (“Anonymized Data”). Anonymized Data may be derived from Data. We hold all rights in and may use Anonymized Data for our own purposes in any manner and without attribution or compensation to any person.
DESCRIPTION OF SERVICES
LAWFUL BASIS FOR PROCESSING
When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard copy, or by clicking “I Accept” or similar language online or through a mobile application, we will process your Data for the purposes of fulfilling the terms of our contract with you. In that case, our processing of your Data is based on the contract, so your withdrawal of consent will only be effective after the purposes for processing that Data have been fulfilled and after we no longer have a legal obligation to keep that Data.
In all cases, we will comply with applicable law and we will cease processing your Data after the legal right, obligation, or other lawful basis expires.
Primary use of the Services is directed to persons 16 years of age or older. Other than for Data processed for the specific purpose of providing the Services to users, we do not knowingly process Data from users who are under 13. If we become aware that we have processed Data from a person under 13, except to provide the Services to such person, and except to the extent allowed or required by law, then we will attempt to delete such Data as soon as possible, subject to our obligations under applicable law. If you believe that we have processed Data from a person under 13 in contravention of this policy or applicable law, please contact us at email@example.com.
DATA WE PROCESS AND HOW WE USE IT
Listed below are categories of Data we process when you use our Services. We always have a lawful basis for processing the Data, but that lawful basis might be different for different categories, and we describe those uses below. Regardless, we never process Data for any purpose other than the purpose for which we processed the Data in the first place, unless we get your prior explicit consent.
A. Registration Data
B. Engagement Data
C. Usage Data
D. Payment Data
1. Data Description: Payment Data is only processed when your use of the Services is subject to the payment of a fee or other charge. Payment Data is the information necessary to process your payments for the Services. Payment Data will vary depending on the payment method you use but will likely include information such as:
Please note that we use third-party providers to process Payment Data. The third party’s tool is layered over our Services, so your credit card information never hits our system. Further, we only use payment processors that are PCI compliant.
2. Lawful Basis for Processing: Our lawful basis for processing Payment Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Payment Data we receive from you.
3. How We Use It and Who We Share It With: We only process Payment Data to facilitate payment, and we only communicate it to those parties who are strictly necessary for that purpose.
E. Supplemental Mobile Data
1. Data Description: Where applicable to the Services, Supplemental Mobile Data consists of the following and similar information:
2. Lawful Basis for Processing: Our lawful basis for processing Supplemental Mobile Data is (1) our contract with you, (2) our obligation to provide you with the Services, and (3) our legitimate interest in improving our Services based on the Supplemental Mobile Data we process.
3. How We Use It and Who We Share It With: We only process Supplemental Mobile Data when you specifically authorize it, and we only share it with those parties who are strictly necessary for the purpose you have authorized.
SHARING YOUR INFORMATION
Except where a specific limitation is noted above, we may share your Data as follows:
If we ever plan to process any Data in the future for any other purposes not identified above and we do not have a separate lawful basis for that new purpose for processing, we will only do so after obtaining your specific consent.
TECHNOLOGIES WE USE
The technologies we use for automatic Data processing may include the following:
“Do Not Track” Options
Your web browser(s) may offer a “Do Not Track” option, which allows the individual to signal to operators of websites and web applications and services (including behavioral advertising services) that he or she does not wish such operators to track certain of his or her online activities over time and across different websites. We do our best to support Do Not Track requests but cannot guarantee full support based on the variety of internet browsers and technologies which means that we may process information about your online activity both while you are using the Services and after your use of the Services.
YOUR RIGHTS REGARDING YOUR DATA
Under applicable data protection, privacy, and other laws, you may have certain rights related to your access and control of your Data. Such rights may include the following:
We may use additional processes to verify your identity before we reveal or delete any of your Data, including two-factor or two-step authentication measures to ensure we can identify you.
Further, although we currently do not process Data without consent, if we at any time in the future process Data without your express consent, you may opt-out or withdraw consent at any time.
Please note that exercising any of the above rights may limit or eliminate our ability to provide you the Services. If so, we may terminate the Services due to such requests.
We will try to comply with your request(s) as soon as reasonably practicable and at the very least as required under applicable law. Upon receipt of your written request, we will provide you with a copy of your information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request.
Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those messages while continuing to use the Services.
Further, you may opt-out or disable certain functions on your particular device, preventing us from processing Data. For example, you may disable geolocation or GPS functionality on your mobile device or disable push notifications. If you disable such features, your ability to use and access the Services may be limited.
To exercise any of these rights, or if you have any questions about our processing of your Data, please contact us at firstname.lastname@example.org.
The security of your Data is important to us. We use commercially reasonable efforts to process your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You can help by keeping us informed of any changes such as a change of your personal contact information. If you would like to access your information, if you have any questions, comments, or suggestions of if you find any errors in our information about you, please contact us at email@example.com. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.