You may provide Us with Personal Information in various ways on the Web Site or through the Platform or the Services. For example, You provide Us with Personal Information when You visit the Web Site, register for an Account, use the Platform, post User Content, interact with other Clients or Users of the Services, or send Us customer service-related requests. When and if You i) visit the Web Site; ii) register for an Account; iii) use Services; iv) otherwise contact Us, We may request, collect and store information from You as provided for hereinabove:
Technical data: Each time when You visit the Web Site, Our servers (or Our subcontractors’ servers) temporarily store information about the accessing agent in a log file. In the course of this procedure, the following data is automatically collected and stored, without any action on Your part, until the time of automatic deletion: the IP address of the accessing computer, the date and time of access, the name and URL, the web site from which access is made, the web sites that You visited just before or after You accessed the Web Site or used the Services, the operating system of Your computer and the browser used by You as well as other technical data, the name of Your internet access provider, Your language configuration and geographical origin (other related data may be collected and stored as well).
Client provided information: If You are a Client, We collect and store Personal Information that specifically identifies You and/or Users authorised by You, as well as Your Account. We may collect and store the following Personal Information:
i) name, email address, phone number, physical contact information and other information of Your Account. For issuance and acceptance of invoices – financial information, such as credit card or bank account numbers and other information You provide to purchase the Services;
ii) additional information We ask You to submit to authenticate Yourself or, if We believe You are violating the Terms (for example, We may ask You to send us an ID or bill to verify Your address, or to answer additional questions online to help verify Your identity);
iii) transactional information based on Your activities on the Platform (such as Your User Content You generate or that relates to Your account);
iv) information about Your device that You use to connect to the Web Site and access the Platform (e.g., personal computer, notebook, mobile phone, etc.) for purposes of the Web Site administration;
v) other information from Your interaction with the Web Site, the Services, content and advertising, correspondence through the Platform, correspondence sent to Us, device ID, connection information, statistics on page views, traffic to and from the Web Site, ad data and standard Web log information;
vi) additional information from You or about You in other ways not specifically described herein (e.g., information related to Your contacts with Supplier’s customer service or results, when You respond to a survey, etc.);
vii) other information You provide on the Web Site, the Platform or the Services, including the ability to receive promotional offers from the Supplier.
Web Site visitors provided information: If You are a Web Site visitor, We may collect and store the following Personal Information:
i) name, email address and other information provided by You through Your contacts with Supplier’s customer service;
ii) additional information We ask You to submit to authenticate Yourself or, if We believe You are violating the Terms (e.g., We may ask You to answer additional questions online to help verify Your identity);
iii) information about Your device that You use to connect to the Web Site (e.g., personal computer, notebook, mobile phone, etc.) for purposes of the Web Site administration;
iv) other information from Your interaction with the Web Site, correspondence sent to Us, device ID, connection information, statistics on page views, traffic to and from the Web Site, ad data and standard Web log information;
v) additional information from You or about You in other ways not specifically described herein (e.g., results, when You respond to a survey, etc.);
vi) other information You provide on the Web Site, including the ability to receive promotional offers from the Supplier.
User Content: As part of the Services, a Client or User may provide Us with User Content, including Personal Data about the Client’s customer or a third person, to store on the Client’s behalf in connection with the Client’s or User’s use of the Services. The Supplier has no direct relationship with the individuals whose Personal Data it hosts as part of User Content. We work with our Clients to help them provide notice to their customers and third persons concerning the purpose for which their Personal Data is collected and how it is processed in the Services as part of User Content.
In the future We may include other optional requests for information from You to help us to adjust the Web Site, the Platform or the Services and to deliver personalized information to You.
3. Integrated Services
4. Processing and Usage
Processing of Personal Information contained in User Content: The Supplier does not own, control or direct the use of any of the information stored or processed by You via the Services. Only the Client or Users are entitled to access, retrieve and direct the use of such information. The Supplier is largely unaware of what information is actually being stored or made available by You to the Platform and the Services and does not directly access such information or data except as authorised by the Client or as necessary to provide Services to the Client.
The Client or the User is the data controller under the Directive for any User Content containing Personal Information, meaning that such party controls the manner such Personal Information is collected and used as well as the determination of the purposes and means of the processing of such Personal Information. The Supplier is not responsible for the content of the Personal Information contained in the User Content or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client or User nor is the Supplier responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
How We use the information We collect: Our primary purpose for collecting Personal Information is to provide You with safe, smooth, efficient and customized Services on the Platform. You agree that We may use Your Personal Information in a variety of ways in providing the Services and operating our business, including the following:
i) to operate, maintain, enhance and provide all features of the Web Site, the Platform and the Services, to provide support and information that You request, to respond to comments and questions, otherwise support You if requested;
ii) to understand and analyse the usage trends and preferences, to meet the needs of our Clients and Users, to improve the Platform and the Services, to develop new products, services, features, tools and functionalities;
iii) to prevent, detect and investigate potentially prohibited or illegal activities on the Web Site or through the Platform;
iv) to inform You about the Web Site, the Platform or the Services, upon Your consent to deliver targeted marketing and newsletters;
v) to resolve troubleshoot problems;
vi) for other purposes as described when We collect appropriate information.
If You shall decide, that You disagree with the use of Your Personal Information by the Supplier, You may submit an appropriate request to Us at any time by sending an email notification to email@example.com, except if otherwise provided by applicable law. After receipt of such request, Your access to the Platform and the Services may be terminated.
Disclosure of Your Personal information: We may disclose Your Personal Information to respond to legal requirements, take precautions against liability, protect the security or integrity of the Platform or the Services and any facilities or equipment used to make the Services available, protect Ourselves or others from fraudulent, abusive, or unlawful uses or activity, enforce Our policies and/or agreements, reply to provided claims or other content, that violates the rights of other third parties, or investigate and protect anyone’s rights, property or safety. Such information will be disclosed in accordance with applicable laws and regulations of the European Union.
You agree that We may also share Your Personal Information, including User Content, with:
i) third party contractors and/or partners who work on behalf of or with the Supplier to provide You with the services of the Web Site, the Platform or the Services, to help the Supplier to communicate with You or to maintain the Web Site, other service providers under contracts concluded with the Supplier, who help with Supplier’s business or Web Site operations (such as payment collection, etc.). Generally, We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and We require them to agree to maintain the confidentiality of such information;
ii) other third parties to whom You explicitly ask Us to send Your Personal Information (or about whom You are otherwise explicitly notified and consent to when using the Platform or the Services);
iii) the affiliates or associated companies, if We shall have any subsidiaries, joint ventures or other companies under a common control in the future;
Disclosure of non-personally-identifiable information: We may make certain automatically-collected, aggregated or otherwise non-personally-identifiable information available to third parties for various purposes, including i) compliance with various reporting obligations; ii) for business or marketing purposes; or iii) to assist such parties in understanding Our Clients’/Users’ interests, habits and usage patterns for certain programs, content, services, and/or functionality available through the Platform and/or the Services.
6. Data retention
We shall have a right to retain Personal Information from terminated or deleted Accounts in order to comply with laws, prevent fraud, collect any fees owed by You, resolve disputes, troubleshoot problems, assist with any investigations, enforce rights under the Terms of Service and take other actions otherwise permitted by laws. Notwithstanding, We will maintain Personal Information on Clients/Users who had their Account terminated for violating the Terms and applicable laws.
7. Information You Share
Your identity on the Platform: Your name (i.e. company name or Your full name), username and Your logo/photo, if uploaded, are displayed throughout the Platform, and is connected to all of Your Platform activities. Meaning that if You associate Your name or other Personal Information with Your Account as part of registration process, people to whom You have revealed Your name or other Personal Information will be able personally identify Your activities on the Platform.
Your password: Your password is the key to Your Account. When creating Your password, please use unique numbers, letters and special characters, and do not disclose Your Account password to anyone. If You do share Your password or Your Account information with others, You are responsible for all actions taken in the name of Your Account at all times, unless it is proven otherwise. In case You access the Platform from a shared computer or a computer in an internet café, certain information about You, such as Your User ID, activity or reminders from the Supplier, may also be visible to other individuals who use the computer after You. If You lose control of Your password, You may lose substantial control over Your Personal Information and may be subject to legally binding actions taken on Your behalf. Therefore, if Your password has been compromised for any reason, You should immediately notify the Supplier and change Your password on the Platform.
8. Your rights
Clients’ rights: We respect Your privacy rights and provide You with reasonable access to Personal Information that You may provide through the Platform. Further, We provide You with the ability to check, review and correct inconsistencies of or to update Your information. You can check, review and amend most of Your Personal Information provided on the Platform by signing on to Your Account and accessing settings page through the Services. We will not manually modify Your Personal Information. Therefore, You must promptly update Your Personal Information, if it changes or is inaccurate.
You may, of course, decline to share certain Personal Information with Us, in which case We may not be able to provide to You some of the features and functionality of the Services. If you wish to access or amend any other Personal Information We hold about You, or to request that We delete any information about You that We have obtained from an Integrated Service, You may contact Us at firstname.lastname@example.org. Please note that while any changes You make will be reflected in active user databases instantly or within a reasonable period of time, We may retain all information You submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations or where We otherwise reasonably believe that We have a legitimate reason to do so.
Other persons’ rights: The Supplier has no direct relationship with the Client’s customer or third party whose Personal Information it may process on behalf of a Client. An individual, who seeks access or who seeks to correct, amend, delete inaccurate data or withdraw consent, should direct his query to the Client or User he deals with directly. If the Client or its authorized User requests the Supplier to remove such data, the Supplier will respond to its request within 30 days. In any event, the Supplier will delete or amend any Personal Information that the Supplier is storing, if it receives a written request to do so, unless the Supplier has a legal right to retain such Personal Information. Any such request should be addressed to email@example.com and include sufficient information for the Supplier to identify the Client or its customer or third party and the information to delete or amend.
9. Marketing, Online Surveys and other
The Supplier does not make Personal Information available to third parties for their use and also does not sell the data to third parties for their marketing purposes without Your explicit consent.
Marketing: Upon Your consent by filling the sign-up form for an Account, Your email address will be used to receive marketing communications about the Web Site, the Platform or the Services, current promotions, newsletters and other. If You decide to opt out of receiving such information, You may request Us at any time by sending an email notification to firstname.lastname@example.org or using other settings on the Platform, if available.
However, You may not opt out of receiving administrative communications from the Supplier regarding the Web Site, the Platform or the Services, except by terminating Your Membership. In addition, You may not opt out of the Supplier sending You legal notices related to Web Site, the Platform or the Services.
Surveys: Occasionally, the Supplier may conduct Client’s or Users’ surveys to collect information about their preferences. These surveys are optional and, if You choose to respond, Your responses shall be kept anonymous, unless in particular case it is stated otherwise. None of this information is shared with third parties, unless stated otherwise.
Third Party Buttons: Additionally, We may implement third party buttons (such as Facebook “like” or “share” buttons) that may allow third parties to collect information about You through such third parties’ browser cookies, even when You do not interact with the button. Information collected through the buttons is collected directly by these third parties, and the Supplier does not participate in that data transmission. Information collected by a third party in this manner is subject to that third party’s own data collection, use and disclosure policies.
Cookies information: When You use the Web Site, the Platform or the Services, We may send one or more cookies – small text files containing a string of alphanumeric characters – to Your device to i) help monitor and analyse the Web Site flow, the effectiveness of Services and third-party marketing activities; ii) customize the Web Site, the Platform, the Services, advertisements, content, and/or information herein; iii) personalize Our services, such as remembering Your information so that You will not have to re-enter it during Your visit or the next time You visit the Platform; iv) track Your entries, submissions and status in any promotions or other activities on the Services; v) monitor aggregate Web Site usage metrics such as total number of visitors and pages viewed; or vi) measure promotional effectiveness and promote trust and safety.
By using the Web Site, the Platform or the Services, You expressly consent to record the cookies by the Supplier on Your computer (or other device). We may use both session cookies and persistent cookies. A session cookie disappears after You close Your browser. A persistent cookie remains after You close Your browser and may be used by Your browser on subsequent visits to the Platform. Please review Your web browser “Help” file to learn the proper way to modify Your cookie settings. Please note that if You delete or choose not to accept cookies from the Services, You may not be able to utilize the features of the Services to their fullest potential.
Please find the main information You should know about cookies below:
iii) most cookies are “session cookies”;
iv) You are always free to decline Our cookies if Your browser permits, although doing so may interfere with Your use of the Web Site, the Platform or the Services;
v) You may encounter cookies from third parties on certain pages of the sites that We do not control.
11. No Spam, Spyware or Spoofing
We may automatically or manually filter Your messages to check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content, but We do not permanently store sent messages. If You send an email to an email address that is not registered through the Platform, We do not permanently store that email or use that email address for any marketing purpose.
Please report spam, spyware or spoof emails to the Supplier by e-mailing to email@example.com.
12. Children’s privacy
Our Services are not directed to children under the age of 18 and We do not knowingly collect Personal Information from children under the age of 18 without obtaining parental consent. If You are under 18 years of age, then please do not use or access the Platform and/or the Services at any time or in any manner. If We learn that Personal Information has been collected through the Platform or the Services from persons under 18 years of age and without verifiable parental consent, then We will take appropriate steps to delete this information. If You are a parent or guardian and discover that Your child under 18 years of age has obtained an Account on the Platform, then You may alert Us at firstname.lastname@example.org and request that We delete that child’s Personal Information from Our systems.
We are using generally accepted reasonable physical, electronic and procedural measures and methods to safeguard information (including anonymous information) in Our possession against accidental or unlawful destruction, accidental loss, theft and unauthorised access, use, disclosure, modification, as well as any other unlawful form of processing of the Personal Information. Please note that, although We make reasonable efforts to protect Your Personal Information, with current technology, We cannot and We do not guarantee the security of Your Personal Information as it is delivered or collected over the Internet. We cannot ensure or warrant the security of any information you transmit to us or store on the Services, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical or managerial safeguards. If you believe your Personal Data has been compromised, please contact us at email@example.com.
You can reduce the risk of unauthorized access to Your Personal Information by using common sense security practices such as choosing a strong password, using up-to-date antivirus software, etc. If We learn of a security systems breach, then We attempt to notify You electronically so that You can take appropriate protective steps. In case of a security breach, We may inform You by an e-mail and/or posting notice to You on the Platform or otherwise making available to You on or through the Services.
14. Third Parties
The Supplier does not control privacy policies of third parties and You are subject to the privacy policies of those third parties where they are applicable. The Supplier is not responsible for privacy policies or the content of any other web sites to which the Web Site links or which link to the Web Site. By clicking on a link, logo or other item, or using the Services available through the Web Site, including the online communication services, please note that You may no longer be on the Web Site. Any information you provide on third party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the ServiceS. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
15. Data transfer
16. International Clients
The Services are hosted in the European Union. If You choose to use the Services from other regions of the world with laws governing data collection and use that may differ from European law, then please note that You are transferring your User Content and Personal Information outside of those regions to the European Union for storage and processing. Also, We may transfer Your data from European Union to other countries or regions in connection with storage and processing of data, fulfilling Your requests and operating the Services. By providing any information, including User Content and Personal Information on or to the Services, You consent to such transfer, storage, and processing.
18. Dispute resolution
The rules applicable with respect to the issues of an applicable law and a dispute resolution are indicated in the Terms of Service.
19. Contacting details
We encourage You to help us expand and make improvements to the Web Site, the Platform and the Services by providing Us with any thoughts or comments You might have regarding Our Services or the operation of the Platform. You can submit any comments You have to Us by clicking on the link. The “[…]” page asks for Your email address and name, what will be used only to acknowledge or respond to Your comments and will not cause You to receive any secondary or promotional material, unless specifically requested by You. Under certain circumstances, We may ask for Your permission to post Your comments in marketing or promotional materials.