Effective: November 1, 2021
1. Personal Information We Collect About You. We may collect and use the following information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):
If you do not provide certain personal information, it may delay or prevent us from providing certain services to you.
2. How Your Personal Information is Collected. We collect most of this personal information directly from you—by telephone, text or email, or via our App.
We may also collect information:
3. Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
The information we collect automatically is statistical data and does not include personal information. It helps us to improve our App and to deliver a better service.
5. How and Why We Use Your Personal Information. We may use personal information for the following purposes:
In addition to the foregoing, the table below provides examples of how we may use your personal information and our reasons for such use:
|How we may use your personal information|
|To provide services to you||For the performance of our agreement with you or to comply with your requests|
|To prevent and detect fraud against you or us||For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you|
|Processing necessary to comply with professional, legal and regulatory obligations that apply to our business||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; and to comply with our legal and regulatory obligations|
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Updating and enhancing customer records||To comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products|
Marketing our services to:
|For our legitimate interests, i.e. to promote our business to existing and former customers|
6. Who We Share Your Personal Information With. We will not sell any of your personal information to any outside organization. We only disclose your personal information to third parties as reasonably necessary to carry out the permitted uses described in this policy. For example, we may share personal information with:
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household:
7. Where Your Personal Information is Held.We are based in the United States, and personal information collected by us worldwide (including within the European Economic Area) may be transferred to the United States for processing and storage. For example, we may import your personal information into the United States to fulfill our contractual obligations to you. By providing personal information to us, you consent to the transmission of your information outside your own country to be stored in the United States. We take steps to ensure that any such transfer complies with data protection law and that all personal information is secure, including, where appropriate, putting in place standard contractual clauses or implementing other lawful tools and processes for transferring personal information.
8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
9. European Economic Area (EEA) Residents. If you reside in the European Economic Area (EEA) you may have the following additional rights under the GDPR:
We will not discriminate against you if you choose to exercise any of these rights. You can exercise your rights under the GDPR by contacting us as follows:
Email: firstname.lastname@example.org (please use “GDPR” in the subject line)
The GDPR also gives individuals in the EEA the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
10. California Residents. California consumers have the right to request any of the following information from us regarding personal information collected about you during the preceding 12 months:
We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your California residency), subject to delays and exclusions permitted by law. Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.
As a California resident, you have the right to request that we delete any personal information that we have collected about you. We will honor this request subject to the range of exclusions permitted by law. For example, we are not required to delete personal information if it is necessary to complete a transaction or reasonably used for an ongoing business relationship or if it is used internally in a lawful manner that is compatible with the context in which the consumer provided the information.
As a California resident, you also have the right to opt out of the sale of your personal information to third parties. We do not sell your personal information. However, we are permitted to share your personal information with a service provider.
We will not discriminate against you if you choose to exercise any of these rights. California residents may exercise the rights described above by contacting us as follows:
Email: email@example.com (please use “CCPA” in the subject line)
Phone: (800) 463-1276.
We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.
11. Keeping Your Personal Information Secure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our services. Any transmission of personal information is at your own risk.
12. Treatment of Minors’ Information. Our App is not intended for children and we do not knowingly solicit or collect personal information from children. If we are notified or discover that a child under the age of 13 has submitted personal information to us, we will take reasonable steps to delete the information.
13. Changes to This Privacy Notice. We may update this policy from time to time. We will always post the then-current version of this policy on our App and will indicate at the top of the policy the date on which the latest version took effect. Please review this policy from time to time to stay updated on our privacy practices.
14. How to Contact Us.
15. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).