If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights under the EU General Data Protection Regulation (“GDPR”) with respect to your Personal Data, as outlined below. If you are located in the state of California, you may have additional rights under the California Consumer Privacy Act (“CCPA”).
What Data Do We Collect?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information We Collect From You Directly: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:
Account Information: When you create an Account, you will provide information that could be Personal Data, such as your name, username, password, email address, profile picture, location and company affiliation. You acknowledge that this information may be personal to you, and by creating an Account on the Services and providing Personal Data to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services, but only rarely when we feel such information is important. You may unsubscribe from these messages through your Account settings or via the email communication, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.
Information We Receive From Third Party Sources: Some third parties, such as our business partners and service providers, (including, but not limited to those who provide services related to customer messaging, surveying, advertising, marketing, social media, and analytics), provide us with Personal Data about you, such as the following:
- Platform activity data
- Survey responses
- Account information for third party services
- Information from our advertising partners
- Name and email address from participation in our referral and promotional codes programs
Information We Automatically Collect When You Use Our Services: Some Personal Data is automatically collected when you use our Services, such as the following (but not limited to):
- Your contact information, including your (first and last) name, (billing and/ or delivery) address, email address and telephone number. We need your email address and telephone number so that we may contact you if we have questions or information for you regarding your service/order that we are providing or will provide to you.
- Other information required to be able to process your service request/ order or to provide you with the service, such as information concerning the products you have ordered or the service we are providing to you, the billing and/or delivery address, banking and/ or credit card details.
- If you have created an online profile or account, the preferences and interests stored in such profiles or accounts.
- If you have contacted customer service, the details of your contact and the contact history.
IP Address Information and Other Information Collected Automatically: We automatically receive and record information from your web browser when you interact with the Services, including your IP address, device ID, and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g. what links you have clicked on).
Generally, the Services automatically collect usage information, such as which parts of the Site you use and the number and frequency of visitors to the Site. We may use this data in a manner that would identify you personally. This type of data enables us, and third parties authorised by us to figure out how often individuals use parts of the Services so that we can analyse and improve them.
Email Communications: We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you take advantage of the most attractive features of the Services.
Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our website or Services. We’ve provided a quick summary of some of the cookie types we and our service providers use on the Service, but for more information about cookies, visit http://www.allaboutcookies.org/ or http://www.aboutcookies.org.uk/ .
Essential Cookies: Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Services. Disabling these cookies will make certain features and services unavailable.
Functional Cookies: Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These cookies help us to personalise our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/ Analytical Cookies: Performance/ analytical cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the website, what pages visitors view on our website and how long visitors are viewing pages on the website. Performance/ analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Service’s content for those who engage with our advertising.
Retargeting/ Advertising Cookies: Retargeting/ advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Analytics Data: We collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third-party applications, and other information that assists us in analysing and improving the Services.
Aggregate Information: We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Data. While Aggregate Information is not Personal Data, it may be tied back to you, your Account or your web browser.
How Do We Use Your Personal Data?
We process Personal Data to operate, improve, understand and personalise our Services. For example, we use Personal Data to:
- Operate, maintain and provide our features and services on the Services;
- Respond to user inquiries.
- Provide support and assistance for the Services;
- Personalise content and communications based on your preferences;
- Maintain interoperability with third-party services;
- Conduct online behavioural advertising;
- Remember information so that you will not have to re-enter it during your visit or the next time you visit the Site;
- Comply with our legal or contractual obligations;
- Provide and monitor the effectiveness of our Services;
- Protect against or deter fraudulent, illegal or harmful actions;
- Serve relevant advertisements;
- Monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Services;
- Diagnose or fix technology problems;
- Complete corporate transactions such as mergers and acquisitions; and
- Enforce our Terms of Service.
- We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests”, as further described below.
Contractual Necessity: We process some Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties. Examples of these legitimate interests include: Operation and improvement of the business, products and services Marketing of our products and services Provision of customer support Protection from fraud or security threats Compliance with legal obligations Completion of corporate transactions
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
How, and With Whom, Do We Share Your Data?
The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties. We share your Personal Data in the instances described below.
IP Address Information
Information You Elect to Share
We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Data about you that they have independently developed or acquired.
Email Communications with Us
As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery.
User Profile Information
User profile information including your name and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
As stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may, from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
Information Shared with Our Agents
- Fraud prevention and spam service providers.
- Analytics service providers.
- Hosting service providers.
- Monitoring service providers.
- Data management platforms.
- Security service providers.
- Payment processors.
We also share information with third parties and Agents when you give us consent to do so.
Information Disclosed Pursuant to Business Transfers
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, are acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that are transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
Information Disclosed for Our Protection and the Protection of Others
Is Information About Me Secure?
Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorised access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.
We otherwise store all of your information, including your IP address information, using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. We do not guarantee or warrant that such techniques will prevent unauthorised access to information about you that we store, Personal Data or otherwise.
What Information of Mine Can I Access?
If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/ or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address where appropriate:
For Global Matters:
L6, 276 Flinders Street
For South East Asia Matters:
Privasec, 5 Shenton Way
UIC Building #10-01
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing email@example.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.
What Choices Do I Have Regarding My Information?
- You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.
- You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.
- You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.
If you do not want to receive promotional emails from us, you can click the “unsubscribe” button on the promotional email communications or email us at firstname.lastname@example.org with the subject “Marketing Opt-Out”. Note that you will not be able to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, password reminders, changes or updates to features of the Service, or technical and security notices.
Behavioural Advertising and Tracking Tools
You can opt-out of certain Behavioural Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.
- Industry Opt-Out Tools: Some advertising service providers or providers of tracking tools may participate in the Network Advertising Initiative’s (NAI) Opt-Out Tool (http://www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (DAA) Consumer Choice Page (http://www.aboutads.info/choices/), and you can opt-out of certain services and learn more about your choices by visiting the links included here. Users in the EU can visit http://www.youronlinechoices.eu/ for more information about your choices and to opt-out of participating service providers.
- Web Browser Controls: You can prevent the use of certain tracking tools, such as cookies, on a device-by-device basis using the controls in your web browser. These controls can be found in the Tools > Internet Options (or similar) menu for your browser, or as otherwise directed by your browser’s support feature. Through your web browser, you may be able to: Delete existing Tracking Tools, Disable future Tracking Tools, or set your browser to provide you with a warning each time a cookie or certain other Tracking Tools are being set.
- Mobile Opt-Out: Your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for behavioural advertising. You may also opt-out of certain tracking tools on mobile devices by installing the DAA’s AppChoice app on your mobile device (for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8, for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en). For more information, please visit http://support.apple.com/kb/HT4228, https://support.google.com/ads/answer/2662922?hl=en or http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device, as applicable.
- Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Service and after you leave our Services. We collect certain persistent identifiers from your browser or mobile device to assist us with providing and improving the Services. Because we collect browsing and persistent identifier data (only for analytic and internal purposes), your selection of the “Do Not Track” option provided by your mobile browser will not have any effect on our collection of analytics information or the collection of a persistent identifier.
Please note the following with respect to opting out of Behavioural Advertising:
- Some opt-out features are cookie-based, meaning that when you use these opt-out features, an “opt-out” cookie will be placed on your computer or other device indicating that you do not want to receive Behavioural Advertising from certain companies. If you delete your cookies, use a different browser, or use a different device, you will need to renew your opt-out choice.
- Opting out of Behavioural Advertising does not mean that you will no longer receive online ads. It only means that such ads will no longer be tailored to your specific viewing habits or interests. You may continue to see ads on and about the Services.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services, and for an additional two years or until we receive a request to delete it. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalised or aggregated form but not in a way that would identify you personally.
Transfers of Personal Data
The Services are hosted and operated in either of our Australia, New Zealand, Malaysia or Singapore branches through privasec.com and its service providers, and laws from our Service provision countries may differ from where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Privasec.
If you are located in the EU, the United Kingdom, Lichtenstein, Norway, or Iceland, and use or access the Services, you may have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email email@example.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.
- Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging into your account.
- Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
- Erasure: You can request that we erase some or all of your Personal Data from our systems.
- Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
- Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
- Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
- Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
- Right to File Complaint: You have the right to lodge a complaint about Privasec’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
What If You Have Questions or Concerns Regarding Your Personal Data?
For Global Matters:
L6, 276 Flinders Street
For South East Asia Matters:
Privasec, 5 Shenton Way
UIC Building #10-01