Effective Date: July 8, 2022
Last Updated: July 8, 2022
If you reside in the European Union (EU), European Economic Area (EEA) or the United Kingdom (UK) you should also refer to the section headed ‘ Additional Information for Users in the EU and the UK ’ at the end of this Policy.
Information We Collect About You
We collect information about you directly from you and automatically through your use of our Site and Services.
Information We Collect Directly From You
The information we collect from you depends on how you use and interact with our Services.
- Visitors. If you visit our Site, you can passively view content we host, such as our videos and other multimedia content. However, you will not be able to create your own content, or otherwise interact with or provide feedback on the content others have created and that we host.
- Contact Information and Communications. If you contact us, we collect records and copies of your correspondence, including your name, e-mail address, and other contact information. We also collect any information you choose to e-mail or communicate to us while using the Services.
- Purchase Information. If you purchase, receive, transfer, trade, exchange or display goods or Services through the Site, we will collect information as necessary to provide the requested goods or Services. This may include you name, e-mail address, physical address, and contact information and other information for physical goods.
Information We Collect Automatically
We automatically collect information about your use of our Site and Services through cookies and other technologies. To the extent permitted by applicable law, we may combine this information with other information we collect about you, including your personal information. For example, when you visit our Site or use our Services, we automatically collect certain network activity and usage information, such as your IP address.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- Transactional Purposes. For transactional purposes, such as to operate our business and provide our Services and physical goods to you.
- Communication and Support. For customer support purposes, such as to communicate with you about your use of our Services and to respond to your inquiries.
- Administration: For administrative purposes, including to help us to maintain security and operability of our Site and App (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Policy, our Terms of Service and other policies.
- For research and analytics purposes, including to measure, improve, and better understand how users access and use our Site and Services.
- Business Transfers. As part of our contemplated or actual acquisition, merger or investment, sale of shares or assets, or a bankruptcy or insolvency proceeding.
- Legal Compliance. We may use information to comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.
- Other Operational and Business Purposes. We may use information for purposes not provided for in this Policy, but if we do, we will notify you (and, if necessary, obtain your consent) before using your information in this way.
How We Share Your Information
We may share your information, including personal information, in the following circumstances:
- Service Providers. We may disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf, such as entities that host our Site and provide information technology and other services related to our Services. We may also disclose information to our commercial partners who will be providing you with physical goods.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries.
- Business Transfers. If (i) we are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our shares or assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain information with lenders, auditors, and advisors, including attorneys and consultants.
- In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- With Your Permission. We may disclose information in ways not described above. If we do so, we will notify you and, if necessary, obtain your consent.
- Cookies. A cookie is a small alphanumeric identifier that is placed on your website browser when you visit a website. Cookies are transferred to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session while accessing our Site and Services. This allows us to display content and provide our Services to you while navigating our Site.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track statistical information about user activity.
Disabling Cookies. Most website browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “Help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function. For more information on how you can customize your browser’s cookie setting, please visit the link to your web browser below:
We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or programs.
Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track activities of Site visitors, and to help us manage content on our Site and Services.
Do-Not-Track. Some web browsers offer a “Do-Not-Track” setting you can activate to signal your preference not to have data about your online browsing activities monitored and collected. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Our Site and Services may contain links to unaffiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
Our Site and Services are not designed for children under thirteen (13). Accordingly, we do not knowingly collect information online from children under 13. If we discover that a child under 13 has provided us with information, we will delete such information from our systems.
Changes to this Policy
If you have any questions about our Policy or would like to make a complaint, you can contact us by emailing us at email@example.com.
Additional Information for Users in the EU and the UK
International Transfers of Your Personal Information
We will take all necessary measures to ensure that transfers out of your country are adequately protected as required by applicable data protection law. With respect to transfers to third party recipients in countries not providing an adequate level of data protection, we may base the transfer on appropriate safeguards, such as the EU standard contractual clauses adopted by the European Commission, the UK International Data Transfer Agreement or Addendum, or other approved data transfer or certification mechanisms together with binding and enforceable commitments of the recipient. In each instance, we will review the transfer and ensure that any additional technical and organizational measures are put in place to ensure that an adequate level of protection is provided. You are entitled to receive a copy of any documentation showing the suitable safeguards that have been taken by making a request using the contact details provided in the ‘Contact Us’ section above.
Communication and Support
Legitimate interest in responding to your inquiries
Legitimate interest in understanding how our Site and Services are used in order to make improvements
Consent (for the placement of non-essential cookies and the subsequent use of non-essential cookie data for analytics or marketing purposes)
Legitimate interest in undertaking a business transfer
Compliance with legal obligation in relation to any court-mandated insolvency process
Compliance with a legal obligation
Other Operational and Business Purposes
Where we refer to ‘legitimate interests’ as the legal basis, we take steps to ensure that our interest is not overridden by our interests, rights or freedoms.
We will obtain prior consent to send you electronic direct marketing by email, SMS or direct message, except where we collect your contact details in the course of selling you a Service, in which case we may instead give you the option to opt-out of direct marketing, as permitted by applicable law.
Where you currently receive direct marketing of any kind you can opt-out at any time by following the instructions in the marketing communication or by contacting us at firstname.lastname@example.org.
We retain your personal information for as long as required to satisfy the purpose for which it was collected and used (for example, for the time necessary for us to provide you with customer service, answer queries or resolve technical problems), unless a longer period is necessary to comply with legal obligations (such as fiscal or legal obligations) or to defend a legal claim. If you would like to receive further information on how long we store your personal information, please contact us using the contact details provided in the ‘Contact Us’ section and specify your request.
Subject to the conditions set forth in the applicable law of your jurisdiction, you have the right to access, right to rectification, right to erasure, right to restrict data processing, right to object against profiling and processing, right to lodge a complaint with your local supervisory authority and your right to data portability.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which the company is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defense of legal claims;
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to data portability
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EU or the UK, as applicable.
We may redact data transfer agreements to protect commercial terms.
Right to withdraw consent
You may withdraw consent (where such consent was obtained and relied on as the legal basis).
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority in the country where you live or work or where you believe your rights have been infringed, if you have concerns about how we are processing your personal information or if you believe that your data protection rights have been violated.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Further, to the extent we rely on legitimate interests to process your personal information, you have the right to object to such use (unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims).
Finally, in the event your personal information is processed on the basis of your consent, you can withdraw consent at any time by contacting us, using the contact details provided below, without affecting the lawfulness of processing based on consent before its withdrawal.
If you have any questions or if you wish to exercise one of your rights under applicable local privacy laws or submit any objections regarding the processing of your personal information, please use email@example.com and specify your request. Please note that we may need to request additional information from you to confirm your identity, and we may extend the time taken to respond to your request if it is complex, or levy a fee, or refuse to comply with a request, if it is manifestly unfounded or excessive.