ARTICLE 1 OUR APPROACH TO PRIVACY
ARTICLE 2 SUMMARY
2.01 We collect information that you provide to us or voluntarily share with other users, in addition to general technical information that is automatically collected by our systems, including IP addresses, browser information and cookies to provide a better user experience and generally improve the Service. 2.02 Your personal information may be gathered from subscribers of the Service, websites you use that we operate, and third parties. Technical information about how you access and use the service, as well as information about your device, is automatically collected and used for Service operation, optimization, analytics, content promotion and enhancement of user experience. In accordance with applicable local law, we may use your information to contact you with relevant information about the Service and our other products and services. 2.03 We do not disclose your personal information to others except as described in this Policy or in connection with the Service. Information that you choose to publish on our Website or social media accounts (blogs, testimonials, videos, text, music, reviews, deliveries) may be read, collected and used by others who access them. 2.04 All of the information that you provide to us is stored on secure servers in a controlled environment with limited access. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in. These international transfers are made pursuant to appropriate safeguards to protect your personal information. 2.05 You may exercise your rights in respect of your personal information that we hold by contacting us at firstname.lastname@example.org. Additional information regarding the rights applicable to you are in the detailed terms of the Policy below. 2.06 The above-noted summary contains highlights of our policy. We encourage you to read more about the information we collect and how we use it in the detailed terms of our Policy below.
ARTICLE 3 DETAILED TERMS
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT 3.01 Information you give to us. We collect personal information about you when you voluntarily submit information directly to us by filling in forms on our Website or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use our Website, subscribe to the Service, participate in any discussion boards, forums or other social media functions on our site or enter a competition, promotion or survey, and when you report a problem with our Website, or use some other feature of the Service as available from time to time. 3.02 If you choose not to provide personal information, we may not be able to provide the Service to you or respond to your other requests. 3.03 Information we receive from other sources. We may receive personal information about you from individuals or corporate entities which are subscribers to the Service (“Subscribers”) where you are to be designated a user of the Service. We may receive personal information about you if you use any of the other websites we operate or the other services we provide from time to time. We also work closely with third parties (including, for example, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them, subject to your agreements with them. 3.04 The following table (“Table 1”) sets out the categories of personal information you provide to us and that we receive from other sources, how we use that information, and the legal basis which we rely upon to process the information and determine applicable retention periods: Personal Information We Collect
|Category of Personal Information||How We Use It||Legal Basis for the Processing|
|Contact information and basic personal details. Your name, phone number, address, location, IP address, e-mail address and where applicable, professional details.||We use this information to communicate with you, including sending statements, recruiting, news, alerts and marketing communications.||The processing is necessary for our legitimate interests, namely for marketing purposes, and for communicating with you effectively and responding to your queries.|
|We use this information to deal with inquiries and other requests made by or about you, including customer service issues, relating to the Service.|
|We use this information to operate, maintain and provide to you the features and functionality of the Service.||The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms of Service).|
|Email account username and password.||Where you have chosen to import contacts from your Outlook or other email account address book to invite them to become members of our Website, we collect the username and password for the email account you wish to import your contacts from||The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely our Terms of Service).|
|Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, or when you interact with customer service, we will record your comments and opinions.||To address your questions, issues, and concerns and resolve your customer service issues.||The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues.|
|Payment information. Details such as your credit card or other financial information including credit scores obtained from credit reference agencies.||We use this information to facilitate payment for use of the Service, to assess your credit score and to detect and prevent fraud.||The processing for assessing your credit score and facilitating payment is necessary for the performance of our contract with you (namely our Terms of Service). The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.|
|Recruiting details. Contact information and basic personal details (as set out above); professional details and employment information such as resume, references, LinkedIn profile.||We use this information to facilitate recruiting.||The processing is necessary for our legitimate interests, namely assessing your suitability for a role with us.|
|All personal information set out above.||We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to monitor and improve the Service, our Website and business, for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to keep the Website safe and secure and to help us develop new products and services.||The processing is necessary for our legitimate interest, namely to administer and improve the Service, our business and develop new services.|
3.05 The following table (“Table 2”) sets out the categories of personal information we collect about you automatically, how we use that information, and the legal basis which we rely upon to process the information and determine applicable retention periods: Personal Information Collected Automatically
|Category of Personal Information||How We Use It||Legal Basis for the Processing|
|Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our Website, your social media profiles, how frequently you access the Service, the time you access the Service and how long you use it for, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service. We also gather information, which may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.||We use this information to: •Conduct market analysis, monitor the Service and how it is used in order to improve our business and help us develop new products and services; •Generate marketing leads and determine news, alerts and other products and services that may be of interest to you for marketing purposes.||The processing is necessary for our legitimate interests, namely: to conduct relevant analysis to improve the Service generally and for marketing purposes.|
|Information about your device. We also collect information about the computer, tablet, smartphone or other electronic devices you use to connect to the Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers, and applications connected to the Service through the device, your Internet service provider or mobile network, your IP address.||We use this information to: •Enable the Service to be presented to you on your device; and •Operate, maintain and provide to you the features and functionality of the Service. We use this information to monitor and improve the Service and business and to help us develop new products and services.||The processing is necessary for the performance of a contract (namely our Terms of Service). The processing is necessary for our legitimate interests, namely to tailor the Service to the user and to improve the Service generally.|
3.06 We may link or combine the personal information we collect and/or receive about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us. 3.07 We may anonymize and aggregate any of the personal information we collect (so that it does not identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Service and developing new products and features. We may also share such anonymized information with others.
ARTICLE 4 DISCLOSURE OF YOUR PERSONAL INFORMATION
ARTICLE 5 MARKETING AND ADVERTISING
5.01 From time to time we may contact you with relevant information about the Service and our other products and services. Most messages will be sent electronically. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you. 5.02 If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can also change your marketing preferences at any time by emailing us at email@example.com or by following the unsubscribe link at the bottom of our emails.
ARTICLE 6 STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
ARTICLE 7 RETAINING YOUR INFORMATION
7.01 We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements. 7.02 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
ARTICLE 8 YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
ARTICLE 9 COOKIES AND SIMILAR TECHNOLOGIES
ARTICLE 10 LINKS TO THIRD PARTY SITES
10.01 The Service may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites. 10.02 Some of the pages on our Website may utilize framing techniques to serve content to/from our partners while preserving the look and feel of our Website. Please be aware that you are providing your personal information to these third parties and not us.
ARTICLE 11 USE OF SERVICES BY MINORS
ARTICLE 12 YOUR CANADIAN PRIVACY RIGHTS
12.01 The Personal Information Protection and Electronic Documents Act Schedule 1 Clause 4.9 permits Canadian residents that are users of our website to request certain information regarding the existence, use, and disclosure of personal information and authorizes access to that information. To make such a request, please send an email to firstname.lastname@example.org.
ARTICLE 13 CHANGES TO THIS POLICY
ARTICLE 14 NOTICE TO YOU
ARTICLE 15 CONTACTING US