1. Websites Covered
2. Information We Collect
3. Use of Collected Information
We use personal information to establish and enhance our relationship with you. We may use personal information to operate, provide, improve, and maintain the Company Websites; to prevent abusive and fraudulent use of the Company Websites; to personalize and display content on the Company Websites; where permitted by applicable law, to send you information, including via email, about our products and Services in which we believe you may be interested; to respond to your inquiries and for other customer service purposes; and for other administrative and internal business purposes. We may use your e-mail address, including any email address provided at through the Company Websites as set forth in the "Communications and Unsolicited Marketing Communications" section. On the Company Websites, we may use passively collected data to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the Company Websites; and (b) monitor aggregate website usage metrics such as total number of visitors and pages viewed.
4. Disclosure of Collected Information
We do not sell or rent email addresses and other personal information that we collect directly through the Company Websites. Please be aware, however, that any information that you voluntarily choose to display on any publicly available portion of the Company Websites, or on any Service, becomes publicly available and may be collected and used by us or others without restriction. We share your information, including personal information, as follows:
Our Company Service Providers
We may disclose personal information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law. Additionally, we may disclose personal information where we, in good faith, deem it appropriate or necessary to prevent violation of the Company Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of Our Company, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies. Aggregate Information and Non-Identifying Information We may share aggregated information with Clients, prospective Clients, partners or the press in order to demonstrate usage of the Service, identify industry and advertising trends, and to generate publicity for the Company Services.
5. Your Choices
On the Company Websites
You may, as a visitor to our website, choose not to provide us with personal information. You may also, at any time, access your personal information to update, correct, or delete certain personal information about you by contacting us in the "Contact Us" section. You also have the right to obtain from Company the erasure of personal data about you in accordance with applicable data privacy laws. In addition you may decide not to opt–in, either when you first provide Company with any personal information, to receive marketing information from Company about products and Services (including our products and Services and those of third parties). See also Section 6, "Communications and Unsolicited Marketing Communications", for additional information regarding changing your preferences or opting out of receiving marketing information. Please be aware that even if you update or remove personal information that you have provided to us, your personal information may be retained in our backup files and archives for a reasonable period of time for legal purposes.
6. Communications and Unsolicited Marketing Communications
If you opted in to receive communications from us we may send you administrative messages and updates regarding your account, updates regarding the Company Websites, and, where permitted by applicable law, information regarding our offer, products and Services, including, without, limitation, through social media updates, by email and postal mail. If you no longer want to receive commercial email messages, you may indicate your preferences regarding commercial email messages by taking the steps described in such messages. Also, you may indicate your preferences regarding commercial email messages and postal mail messages by contacting us using the information in the "Contact Us" section below.
7. Client Data
We collect, use, and retain certain information at the direction and on behalf of our Clients from individuals ("End Users") who use the Client website (Client Data). Company has no relationship with such End Users whose Client Data we process on behalf of our Clients. We also do not decide how the Clients use such Client Data. Company does not access and use the Client Data, except at directed by our Clients or required by law. Information Collected Directly Through Use of the Services about End Users: We collect two types of data about End Users: (1) information that is passed through the Service as a result of use of the Website and (2) technical data automatically collected from all visitors to pages of your website that load the Services. The information that we collect on your behalf depends on the particular Services to which you subscribe and your preferences. Social network and/or identity providers are hosted by a third party and on our Client's service. The Client's and the End User's interaction with these features are governed by the privacy statement of the company providing it. End User Information: We maintain no rights to use any End User Personal Information transmitted to us on your behalf through the Company Website or received from the social networks, except to make the Services available to you and/or End User. We use the information that we collect automatically about the use of our Website to facilitate delivery of the Service and, in some cases, for internal reports. Additionally, some of the information collected is used in the Client Reports. The Client Reports may contain both passively-collected information and End User Personal Information. If you are a customer of one of our Client's, and you want to edit or delete any information captured about you on that Client's website, you should contact the Client directly.
8. International Users
The Company Websites are hosted in London, and we may use service providers in the London and elsewhere to process personal information on our behalf. By using our Websites, you are agreeing that your personal data may be transferred to the UK and other jurisdictions, as explained in this Section.
9. EU, Switzerland and the Data Privacy Shield Framework
Our Company complies with the E.U.- U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information obtained from European Union member countries and Switzerland in conjunction with its contractual relationship with Gigya. Company is a sub-processor for Clients websites that utilize our Services and certifies its processing of personal information from E.U. member countries and Switzerland is in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the "Principles"). You may view the certification for which Company adheres to through its Solution Partnership with Gigya here https://www.privacyshield.gov/list. Gigya and its subsidiaries are subject to the investigatory and enforcement authority of the Federal Trade Commission. Information We Process. We collect, in accordance with the Privacy Shield principles, the categories of information described in sections 2 and 7 above. We process personal information about website users for the purposes described in section 3 above. E.U. and Swiss End Users whose personal information we process on behalf of a Company Client (as a data processor) should first contact the Company Client, who is the controller of your personal information, to access their personal information; Company will work with its Clients to provide End Users the necessary access about what personal information is processed. Transfers to Third Parties. As described in the "Disclosure of Collected Information" section above, we may transfer personal information from the E.U. and Switzerland to third parties. We contractually require third parties to whom we transfer personal information to provide the same level of protections as the Principles. Company remains responsible for the personal information we receive and transfer under Privacy Shield as it relates to our Services. In accordance with our legal obligations, we may also transfer, subject to a lawful request, personal information to public authorities for law enforcement or national security purposes. Contacting Us, Complaints and Dispute Resolution. E.U. and Swiss individuals who have questions or complaints about how we process their personal information may contact us . We will work to resolve your issue and respond no later than 45 days of receipt.
The security of your information is important to us, including, but not limited to, the personal information collected via the Company Websites and Services. We use reasonable security measures to protect against the loss, misuse, and alteration of Personal information under our control, both during the transmission and once we receive it. This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such personal information, no method of transmission over the Internet or method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration. Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining this information. Our data protection officer is: Giovanni Sarto at 3Bit s.r.l. via Savona 125, 20144 Milano ( Italy )
The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. Our Company's Websites are not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personally identifying information through our websites. Additionally, we do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. If we learn that personal information has been collected from a user under 13 years of age on or through the Company Websites, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has registered on the Company Websites or you believe has otherwise provided personal information to Our Company, please contact Company to have that child's account terminated and information deleted.
In addition, we use Google Analytics to analyze our users' use of the Company Websites. Google Analytics is currently on www.polidora.com and www.gdpr-wp.com. Google Analytics provides us with aggregated data in order to help us make informed business decisions. Ultimately, Google, as a third party, controls information collected through Google Analytics and you should check and be comfortable with its privacy practices prior to using the Company Websites. You may review information about Google's privacy practices with respect to Google Analytics at http://www.google.com/analytics/learn/privacy.html.
13. Third-Party Ad Networks
15. Contact Us