PRIVACY NOTICE
Last updated __________
This privacy notice for __________ ("we," "us," or "our"), describes how
and why we might collect, store, use, and/or share ("process") your
information when you use our services ("Services"), such as when you:
Visit our website, or any website of ours that links to this privacy
notice
Engage with us in other related ways, including any sales, marketing, or
events
Questions or concerns? Reading this privacy notice will help you
understand your privacy rights and choices. If you do not agree with our
policies and practices, please do not use our Services.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can
find out more details about any of these topics by clicking the link
following each key point or by using our table of contents below to find
the section you are looking for.
What personal information do we process? When you visit, use, or
navigate our Services, we may process personal information depending on
how you interact with us and the Services, the choices you make, and the
products and features you use. Learn more about personal information you
disclose to us.
Do we process any sensitive personal information? We do not process
sensitive personal information.
Do we collect any information from third parties? We do not collect any
information from third parties.
How do we process your information? We process your information to
provide, improve, and administer our Services, communicate with you, for
security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do
so. Learn more about how we process your information.
In what situations and with which parties do we share personal
information? We may share information in specific situations and with
specific third parties. Learn more about when and with whom we share
your personal information.
What are your rights? Depending on where you are located geographically,
the applicable privacy law may mean you have certain rights regarding
your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights
is by submitting a data subject access request, or by contacting us. We
will consider and act upon any request in accordance with applicable
data protection laws.
Want to learn more about what we do with any information we
collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when
you register on the Services, express an interest in obtaining information
about us or our products and Services, when you participate in activities
on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we
collect depends on the context of your interactions with us and the
Services, the choices you make, and the products and features you use. The
personal information we collect may include the following:
names
email addresses
job titles
usernames
passwords
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you
choose to make purchases, such as your payment instrument number, and the
security code associated with your payment instrument. All payment data is
handled and stored by __________. You may find their privacy notice
link(s) here: __________.
Social Media Login Data. We may provide you with the option to register
with us using your existing social media account details, like your
Facebook, X, or other social media account. If you choose to register in
this way, we will collect certain profile information about you from the
social media provider, as described in the section called "HOW DO WE
HANDLE YOUR SOCIAL LOGINS?" below.
All personal information that you provide to us must be true, complete,
and accurate, and you must notify us of any changes to such personal
information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and
to comply with law. We may also process your information for other
purposes with your consent.
We process your personal information for a variety of reasons, depending
on how you interact with our Services, including:
To facilitate account creation and authentication and otherwise manage
user accounts. We may process your information so you can create and log
in to your account, as well as keep your account in working order.
To save or protect an individual's vital interest. We may process your
information when necessary to save or protect an individual’s vital
interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is
necessary and we have a valid legal reason (i.e., legal basis) to do so
under applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate business
interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to
explain the valid legal bases we rely on in order to process your personal
information. As such, we may rely on the following legal bases to process
your personal information:
Consent. We may process your information if you have given us permission
(i.e., consent) to use your personal information for a specific purpose.
You can withdraw your consent at any time. Learn more about withdrawing
your consent.
Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate
with a law enforcement body or regulatory agency, exercise or defend our
legal rights, or disclose your information as evidence in litigation in
which we are involved.
Vital Interests. We may process your information where we believe it is
necessary to protect your vital interests or the vital interests of a
third party, such as situations involving potential threats to the safety
of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission
(i.e., express consent) to use your personal information for a specific
purpose, or in situations where your permission can be inferred (i.e.,
implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable
law to process your information without your consent, including, for
example:
If collection is clearly in the interests of an individual and consent
cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary
to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with
next of kin
If we have reasonable grounds to believe an individual has been, is, or
may be victim of financial abuse
If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and the
collection is reasonable for purposes related to investigating a breach of
an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order,
or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment,
business, or profession and the collection is consistent with the purposes
for which the information was produced
If the collection is solely for journalistic, artistic, or literary
purposes
If the information is publicly available and is specified by the
regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in
this section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may
share your data with third-party vendors, service providers, contractors,
or agents ("third parties") who perform services for us or on our behalf
and require access to such information to do that work.
The third parties we may share personal information with are as follows:
We also may need to share your personal information in the following
situations:
Business Transfers. We may share or transfer your information in
connection with, or during negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a portion of our business to
another company.
Affiliates. We may share your information with our affiliates, in which
case we will require those affiliates to honor this privacy notice.
Affiliates include our parent company and any subsidiaries, joint venture
partners, or other companies that we control or that are under common
control with us.
Business Partners. We may share your information with our business
partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect
and store your information.
We may use cookies and similar tracking technologies (like web beacons and
pixels) to gather information when you interact with our Services. Some
online tracking technologies help us maintain the security of our Services
and your account, prevent crashes, fix bugs, save your preferences, and
assist with basic site functions.
We also permit third parties and service providers to use online tracking
technologies on our Services for analytics and advertising, including to
help manage and display advertisements, to tailor advertisements to your
interests, or to send abandoned shopping cart reminders (depending on your
communication preferences). The third parties and service providers use
their technology to provide advertising about products and services
tailored to your interests which may appear either on our Services or on
other websites.
To the extent these online tracking technologies are deemed to be a
"sale"/"sharing" (which includes targeted advertising, as defined under
the applicable laws) under applicable US state laws, you can opt out of
these online tracking technologies by submitting a request as described
below under section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?"
Specific information about how we use such technologies and how you can
refuse certain cookies is set out in our Cookie Notice.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our Services using a
social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your
third-party social media account details (like your Facebook or X logins).
Where you choose to do this, we will receive certain profile information
about you from your social media provider. The profile information we
receive may vary depending on the social media provider concerned, but
will often include your name, email address, friends list, and profile
picture, as well as other information you choose to make public on such a
social media platform.
We will use the information we receive only for the purposes that are
described in this privacy notice or that are otherwise made clear to you
on the relevant Services. Please note that we do not control, and are not
responsible for, other uses of your personal information by your
third-party social media provider. We recommend that you review their
privacy notice to understand how they collect, use, and share your
personal information, and how you can set your privacy preferences on
their sites and apps.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in
countries other than your own.
Our servers are located in. If you are accessing our Services from
outside, please be aware that your information may be transferred to,
stored, and processed by us in our facilities and by those third parties
with whom we may share your personal information (see "WHEN AND WITH WHOM
DO WE SHARE YOUR PERSONAL INFORMATION?" above), in and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom
(UK), or Switzerland, then these countries may not necessarily have data
protection laws or other similar laws as comprehensive as those in your
country. However, we will take all necessary measures to protect your
personal information in accordance with this privacy notice and applicable
law.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the
purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary
for the purposes set out in this privacy notice, unless a longer retention
period is required or permitted by law (such as tax, accounting, or other
legal requirements). No purpose in this notice will require us keeping
your personal information for longer than .
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if
this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is
possible.
9.DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children
under 18 years of age.
We do not knowingly collect, solicit data from, or market to children
under 18 years of age, nor do we knowingly sell such personal information.
By using the Services, you represent that you are at least 18 or that you
are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information
from users less than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to promptly delete
such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at __________.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some
regions, such as the European Economic Area (EEA), United Kingdom (UK),
Switzerland, and Canada, you have rights that allow you greater access to
and control over your personal information. You may review, change, or
terminate your account at any time, depending on your country, province,
or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have
certain rights under applicable data protection laws. These may include
the right (i) to request access and obtain a copy of your personal
information, (ii) to request rectification or erasure; (iii) to restrict
the processing of your personal information; (iv) if applicable, to data
portability; and (v) not to be subject to automated decision-making. In
certain circumstances, you may also have the right to object to the
processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section "HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable
data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully
processing your personal information, you also have the right to complain
to your Member State data protection authority or UK data protection
authority.
If you are located in Switzerland, you may contact the Federal Data
Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process
your personal information, which may be express and/or implied consent
depending on the applicable law, you have the right to withdraw your
consent at any time. You can withdraw your consent at any time by
contacting us by using the contact details provided in the section "HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the
processing before its withdrawal nor, when applicable law allows, will it
affect the processing of your personal information conducted in reliance
on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or setting you can
activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your choice
not to be tracked online. If a standard for online tracking is adopted
that we must follow in the future, we will inform you about that practice
in a revised version of this privacy notice.
California law requires us to let you know how we respond to web browser
DNT signals. Because there currently is not an industry or legal standard
for recognizing or honoring DNT signals, we do not respond to them at this
time.
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of, you may have the right to request
access to and receive details about the personal information we maintain
about you and how we have processed it, correct inaccuracies, get a copy
of, or delete your personal information. You may also have the right to
withdraw your consent to our processing of your personal information.
These rights may be limited in some circumstances by applicable law. More
information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the
past twelve (12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal address, telephone or
mobile contact number, unique personal identifier, online identifier,
Internet Protocol address, email address, and account name
NO
B. Protected classification characteristics under state or federal law
Gender, age, date of birth, race and ethnicity, national origin, marital
status, and other demographic data
NO
C. Commercial information
Transaction information, purchase history, financial details, and payment
information
NO
D. Biometric information
Fingerprints and voiceprints
NO
E. Internet or other similar network activity
Browsing history, search history, online behavior, interest data, and
interactions with our and other websites, applications, systems, and
advertisements
NO
F. Geolocation data
Device location
NO
G. Audio, electronic, sensory, or similar information
Images and audio, video or call recordings created in connection with our
business activities
NO
H. Professional or employment-related information
Business contact details in order to provide you our Services at a
business level or job title, work history, and professional qualifications
if you apply for a job with us
NO
I. Education Information
Student records and directory information
NO
J. Inferences drawn from collected personal information
Inferences drawn from any of the collected personal information listed
above to create a profile or summary about, for example, an individual’s
preferences and characteristics
NO
K. Sensitive personal Information
NO
We may also collect other personal information outside of these categories
through instances where you interact with us in person, online, or by
phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your
inquiries.
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT
INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
Learn about how we use your personal information in the section, "HOW DO
WE PROCESS YOUR INFORMATION?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider. Learn
more about how we disclose personal information to in the section, "WHEN
AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such
as for undertaking internal research for technological development and
demonstration. This is not considered to be "selling" of your personal
information.
We have not sold or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. We
have disclosed the following categories of personal information to third
parties for a business or commercial purpose in the preceding twelve (12)
months:
The categories of third parties to whom we disclosed personal information
for a business or commercial purpose can be found under "WHEN AND WITH
WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
Your Rights
You have rights under certain US state data protection laws. However,
these rights are not absolute, and in certain cases, we may decline your
request as permitted by law. These rights include:
Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for
targeted advertising, the sale of personal data, or profiling in
furtherance of decisions that produce legal or similarly significant
effects ("profiling")
How to Exercise Your Rights
To exercise these rights, you can contact us by submitting a data subject
access request, by emailing us at __________, or by referring to the
contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an
authorized agent to make a request on your behalf. We may deny a request
from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with applicable
laws.
Request Verification
Upon receiving your request, we will need to verify your identity to
determine you are the same person about whom we have the information in
our system. We will only use personal information provided in your request
to verify your identity or authority to make the request. However, if we
cannot verify your identity from the information already maintained by us,
we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to
collect additional information to verify your identity before processing
your request and the agent will need to provide a written and signed
permission from you to submit such request on your behalf.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant
with relevant laws.
We may update this privacy notice from time to time. The updated version
will be indicated by an updated "Revised" date at the top of this privacy
notice. If we make material changes to this privacy notice, we may notify
you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us by
post at:
__________
__________
__________
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the
US, you may have the right to request access to the personal information
we collect from you, details about how we have processed it, correct
inaccuracies, or delete your personal information. You may also have the
right to withdraw your consent to our processing of your personal
information. These rights may be limited in some circumstances by
applicable law. To request to review, update, or delete your personal
information, please fill out and submit a data subject access request.