FEELD - PRIVACY POLICY
Last Modified: 14/11/2023
Feeld Ltd ("Feeld", "we", "our", or "us") is committed to protecting and respecting your privacy.
- OUR APPROACH TO PRIVACY
This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you use our app(s), any website operated by us (including https://feeld.co/), any services we provide or otherwise interact with us (together the “Services”).
If you are a resident of the United States of America (US), please see Annex 3 [LINK] for more information about the categories of personal data that we may collect and the categories of sources from which we may collect such personal data.
- ABOUT US
Feeld Ltd (company no. 08916634) is the data controller of the personal information we hold about you.
Our registered and postal address is James Watson House Montgomery Way, Rosehill Industrial Estate, Carlisle, England, CA1 2UU.
We are registered as a data controller with the UK Information Commissioner’s Office under data protection registration number ZA239970.
Our data protection officer can be contacted at [email protected].
- PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
The table at Annex 1 [LINK] sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis on which we rely to process the personal information. If you are a US resident, please see Annex 3 [LINK] for information about our business or commercial purposes for collecting or disclosing your personal data.
More generally, you may provide us with personal information when you:
- sign up to the app and complete your profile;
- are using our app and/or website;
- link accounts together;
- communicate with us (whether through the app, online, including via social media, or by email)
- communicate with others on the app; and
- answer our surveys or participate in our events, campaigns and partnerships
Social media login
Please note that if you create your account using social media login details (e.g. Facebook), you give permission to that social media platform to share with us your name, profile picture and email address.
Special categories of personal data
Some of the personal information you provide us, including sexual orientation, sexual preferences, and certain other information you may choose to provide as part of using the Services (such as information about your race, ethnicity, politics, religion, philosophical beliefs, health and sex life) will be treated as special category personal data to which additional protections apply under data protection law.
We process such special category personal data because you have chosen to submit that information to our Services. We will not share this data with anyone other than in accordance with this privacy policy.
When completing your profile, or providing information to other members or to us via the Services, you can provide as much or as little detail as you see fit.
By completing and sharing your profile information relating to your sexual life, you give your consent for us to process this information for the purposes of providing our Services.
You can amend your profile and remove this information at any time if you no longer want to share this information.
- DATA RETENTION
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for. 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 unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.
If you have created an account with us, it will be terminated when you decide to terminate your account or after your account has remained paused (“Deactivated”) continuously for 1 year . Typically, a user’s account data is deleted 3 months after termination of their account. Please note, however, that we will continue to retain anonymized transactional records and purchase complaint records. We may also retain your personal information for a longer period in certain circumstances, including in the event of an on-going complaint, in the context of a criminal, financial or regulatory investigation (or similar), if we consider on-going retention is needed to protect the health, safety and wellbeing of Feeld staff, other users or other third parties, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
- RECIPIENTS OF PERSONAL INFORMATION
We may share your personal information with the following (as required in accordance with the uses set out in Annex 1 [LINK] or as otherwise described below):
- Service providers: we may share your personal information with third parties and other service providers that perform services for us or on our behalf, which may include providing app and data hosting, data centre and storage facilities, communications, surveys and chat facilities, user relationship management, social media platforms, marketing communications, advertising, push notifications, customer and technical support, error reporting and fixing, analytics, cybersecurity, verification services and/or fraud prevention, monitoring, user safety and safeguarding.
- Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
- Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and/or the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; (iii) enforce our terms and/or (iv) exercise or protect the rights, property, or personal safety of Feeld, its users or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, online and user safety and credit risk reduction.
- Other members of the Feeld group: where applicable, we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1 [LINK].
If you are a US resident, please see Annex 3 for more information about the categories of third parties to whom we disclose each category of personal data.
- MARKETING AND ADVERTISING
From time to time, we may contact you with information about the Services, including sending you marketing messages and asking for your feedback on our Services.
Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you marketing messages if we have your consent or, if consent is not required under applicable law, you have not opted out of receiving messages from us. You can withdraw your consent, or opt out of receiving further communications at a later date, by clicking on the unsubscribe link at the bottom of our marketing emails or, if you are logged in to the app, toggling your preferences within your account settings.
Unsubscribing from marketing emails will not unsubscribe you from system or legal notifications which we may need to send as part of the Service we provide. From time to time, we may need to contact you by email or via our support team.
- STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
Security. We implement appropriate technical and organisational measures, including encryption, to protect your personal information against accidental or unlawful access, destruction, loss, alteration or damage. All personal information we collect will be stored on our secure servers. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.
Despite these precautions, however, we cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal information.
International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in, where our affiliates and our third party service providers have operations. If you are located in the UK or European Economic Area ("EEA"), your personal information may be transferred outside of the UK and EEA, respectively, to a country which is not recognised by the UK or European Commission as ensuring an adequate level of protection for personal data. These international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard contractual clauses adopted by the European Commission and UK government (as applicable). If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy policy.
- YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
- Right of access. You have the right to obtain access to your personal information.
- Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
- Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
- Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
- Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
- Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent (without affecting the lawfulness of our processing prior to you having withdrawn your consent).
Right to object: you also have the right, in certain circumstances, to object to any processing based on our legitimate interests. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive or toggling your preferences in your account settings. See paragraph 6 for further details.
Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review, remove and edit some of the personal information you have submitted to us by logging into your account on the app.
You also have the right to lodge a complaint to your national data protection authority. If you are in the UK, information on how to contact the Information Commissioner is available at www.ico.org.uk. If you are located in the EU, further information about how to contact your local data protection authority is available at:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a US resident, please see Annex 3 [LINK] for more information about your rights with respect to your personal data.
- COOKIES AND SIMILAR TECHNOLOGIES
Our website uses cookies and similar technologies to distinguish you from other users of our Services. Please refer to our Cookies Policy at Annex 2 [LINK] for more information as to the way in which we use cookies on our website and app.
- INTEREST- BASED ADVERTISING
We participate in interest-based advertising and use third- party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Services, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Services so that we or our advertising partners may play or display ads on our Services you may use, and on other devices you may use.
Typically, but not always, this information is collected through cookies and similar tracking technologies. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn about interest-based advertising and how you may be able to opt -out of some of this advertising and to limit some third- party advertising cookies, you may wish to visit:
- Your Online Choices (http://www.youronlinechoices.com/ )
- Network Advertising Initiative (http://www.networkadvertising.org/)
- Digital Advertising Alliance (http://www.aboutads.info/consumers)
Please note that opting -out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt -out again.
If you are a US resident, you may have the right to opt -out of certain types of internet based advertising. Please see Annex 3 [LINK] for more information.
- LINKS TO THIRD- PARTY SITES
Our app and/or website(s) may, from time to time, contain links to and from third- party websites, including those of our business partners, advertisers, news publications and affiliates. 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 of third-party websites before you submit any information to those websites.
- CHANGES TO THIS POLICY
We may update this privacy policy from time to time, so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
- CHILDREN (17 and under)
You must not use our Services if you are under the age of 18. No one under age 18 may provide any information through our Services. If you are under 18, you must not use any of our services or features, register an account, make any purchases, or provide any information, including but not limited to: your name, address, telephone number, email address, and/or username. We do not knowingly collect personal information relating to anyone under this age. If we learn we have collected or received personal information from an individual under 18, we will promptly delete that information. If you have any information from or about a child under 18, please contact [email protected].
- CONTACTING US
If you have any questions, comments and requests regarding this Privacy Policy, you can contact us:
By post:
FAO Legal Department
James Watson House Montgomery Way,
Rosehill Industrial Estate,
Carlisle,
United Kingdom,
CA1 2UU
By email: [email protected]
This privacy policy was last modified on [INSERT DATE] 2023.
ANNEX 1 – PERSONAL INFORMATION WE COLLECT
Category of personal information
How we use it
Legal basis for processing
Contact details (username, email address and phone number)
Profile details (username, date of birth, gender, sexual orientation, photos, additional information (such as hobbies, preferences and bio) and social media details (if applicable))
Communications data (with other members of the Feeld app and/or Feeld representatives)
To assist you in creating a profiling.
To register you with the Services.
To enable you to use our Services, including:
- discovering, and being discovered by, other members
- communicating with other members
- (where necessary) communicating with us
- managing our relationship with you
- enforcing our Terms of Service
To administer your account (including sending you information regarding changes to our policies, other terms and other administrative information).
Such processing is all necessary to perform our contract with you.
(see row below regarding special category data).
Special category personal data (sexual orientation, sexual preferences and certain other information you may choose to provide as part of using the Services (such as information about your race, ethnicity, politics, religion or creed, sexuality, philosophical beliefs, , health and sex life)
To enable you to use our Services.
Explicit consent (either via exercising options when completing the profile or voluntarily submitting such data to the Services)
Contact details
Technical and Usage data
To verify your identity via SMS or email
It is in our legitimate interests to verify the email address or phone number you have given during registration is yours to ensure the accuracy of the data and for security purposes.
Contact details
Marketing details (such as your marketing preferences)
Communications data
Technical and Usage data
Profile Details
Marketing and advertising (including sending you newsletters and measuring the effectiveness of our marketing).
Consent (if required by law)
Where consent is not required by law, it is in our legitimate interests to study how users use our Services and to grow and market our business
Contact details
Profile details
Communications data
Marketing details
To respond to queries and complaints and provide you with information and materials that you request from us.
To carry out surveys and/or ask for feedback with a view to improving our Services.
It is in our legitimate interests to respond to your queries and provide any information and materials requested in order for you to have a positive experience with us and to maintain good customer relations.
It is in our legitimate interests to understand how our users feel about our Service so we can take steps to improve this.
Contact details
Profile details
Communications data
Marketing details
Communications data
Technical and Usage data
To enable you to partake in a prize draw or competition or similar activity.
It is in our legitimate interests to study how users use our Services and to grow and market our business
Technical information (IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location).
Usage data (including clickstream to, through and from the Services, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, interaction information (such as scrolling, clicks, views and mouse-overs), date and time Services are accessed, and Services navigation and search terms used))
- Analytics (such as analysing usage of the Services)
- Improve the Services to ensure that content is presented in the most effective manner for you
- Marketing and advertising
- To ascertain your preferences
Consent (if require by law).
Where consent is not required by law, it is in our legitimate interests to study how users use our Services and to grow and market our business.
Contact details
Profile details
Communications data
Technical and Usage data
To administer and protect our business and our Services (including troubleshooting, fraud prevention, IT security, data analysis, user safety, testing, system maintenance, support, reporting and hosting of data)
It is in our legitimate interests to monitor the Services and resolve errors to ensure that everything functions properly.
To comply with our legal and regulatory obligations under applicable law.
It is also in our legitimate interests to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
ANNEX 2
FEELD - COOKIE POLICY
We use cookies and similar technologies (“Cookies”) on our website.
- What are cookies?
“Cookies” are small text files, placed on a computer hard drive, that enable websites to remember a particular device. They are widely used to make websites work more efficiently for visitors and to provide web providers with traffic information.
Cookies allow the server to deliver personalized pages for users as cookies remember your preferences and make the interaction between you and the website smoother and more efficient. When users load the website, the browser retrieves their previous activity. This allows the browser to keep the user logged in and many other functions that make the navigation more effective.
Without cookies, we may not be able to provide certain services or features, and our website will not work as efficiently as intended. You can turn cookies off, but if you do this, you may not be able to access some of the website.
- Setting and storing cookies
Cookies may be set either by the website you are visiting (“First-Party cookies”) or by third parties that run content on the website you are viewing (“Third-Party cookies”). They may be stored either for the duration of your visit or for repeat visits.
- Different types of cookies
There are four main types of cookies:
- Strictly necessary cookies: These cookies are essential to enable you to login, navigate around and use the features of a website, or to provide a service requested by you. We do not need to obtain your consent in order to use these cookies.
- Functionality cookies: These cookies allow a website to remember choices you make (such as username, language, or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
- Performance cookies: These cookies collect information about how you use a website, (such as identifying which pages you go to most often), and record difficulties you may experience while using the website, such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
- Targeting cookies or advertising cookies: These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
- Cookie table
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Name
Cookie Type
Provider
Purpose
Duration
Cloudflare (Cloudflare Inc.)
Strictly
Cloudflare (Cloudflare Inc.)
A content delivery network service to help with performance and stability of our infrastructure.
n/a
Google Analytics (Google LLC)
Measurement
Google Analytics (Google LLC)
To distinguish users; to store and count page views and sessions for analytics purposes.
AMP_TOKEN: 1 hour
_ga: 2 years
_gac*: 3 months
_gat: 1 minute
_gid: 1 day
Google Analytics 4
Measurement
Google Analytics 4
Collects event-based data from both websites and apps to better understand the customer journey. For further details: https://support.google.com/analytics/answer/10089681?hl=en
_ga: 2 years
ga*: 2 years
Appsflyer (AppsFlyer Ltd)
Measurement
Appsflyer (AppsFlyer Ltd)
Gather marketing analytics to assist with campaigns.
n/a
Google Analytics with anonymized IP
Measurement
Google Analytics with anonymized IP
See above for Google Analytics
AMP_TOKEN: 1 hour
_ga: 2 years
_gac*: 3 months
_gat: 1 minute
_gid: 1 day
Google Optimize
Measurement
Google Optimize
_gaexp: 3 months
optawcid: 1 day
optawgid: 1 day
optawkid: 1 day
optawmid: 1 day
optexpid: 10 seconds
optutmc: 1 day
Smartlook (Smartsupp.com, s.r.o.)
Measurement
Smartlook (Smartsupp.com, s.r.o.)
To provide analytics and visual insight.
n/a
Intercom (Intercom Inc.)
Advertising
Intercom (Intercom Inc.)
Allows us to manage the opportunity to engage with customers.
intercom-id-*: 10 months
intercom-session-*: 7 days
intercom-test: indefinite
- Other technologies we use
We also use pixels or web beacons in direct marketing emails that we send to you. These pixels track whether our email was delivered and opened, the links within the email were clicked and which pages of our website you have visited. They also allow us to collect information such as your IP address, browser, email client type, logs of past interactions, and other similar details. We use this information to measure the performance of our email campaigns, and for analytics.
You can always opt-out of our marketing communications by unsubscribing or you can email us (see our privacy policy for further details regarding marketing.If you use our app(s) on iOS, a unique identifier (“IDFA”) assigned by Apple to your device may be sent to us, depending on the preferences you have expressed in your device, to track certain activities for advertising purposes.
- Consent to use cookies
We will ask for your permission (consent) to place cookies or other similar tracking technologies on your device, except where these are essential for us to provide you with a service that you have requested.
There is a notice on our home page which describes how we use cookies and requests your consent before we place any non-essential cookies on your device.
- How to manage your cookie settings
There are various ways in which you can manage and control your cookie settings. Please note that, by deleting or blocking cookies, some or all of the websites you visit (or features of them) may not work properly or as effectively.
To find out more about cookies, including how to see which cookies have been set and how to manage and delete them, you can visit the third-party website: www.allaboutcookies.org
- Turning off cookies via your web browser
Most modern web browsers will provide you with some general information about cookies, enable you to see what cookies you have, allow you to delete them all or on an individual basis, and enable you to block or allow cookies for all websites or individually selected websites. You can also normally turn off third-party advertising cookies separately.
Please note that if you adjust your cookie settings via your web browser then, unless you delete or block each cookie individually, the changes will apply to all websites that you visit – not just our website. You will also need to adjust your cookies on a browser-by-browser basis.
- Updates to this cookie policy
We may update this cookie policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons.
The date at the bottom of this cookie policy indicates when it was last updated.
- Contact us
If you have any questions or comments about this cookie policy, or privacy matters generally, please contact us at [email protected].
This cookie policy was last modified on the [INSERT DATE] 2023.
ANNEX 3 – NOTICE TO UNITED STATES RESIDENTS
This Annex 3 is incorporated into the Privacy Policy and includes additional information for residents of the United States regarding the collection and use of their Personal Data. The term “Personal Data,” as used in this Annex 3, includes “personal information” and “sensitive personal information” as defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”).
PERSONAL DATA
The following subsections detail the categories of Personal Data, including categories of sensitive personal information, that we collect and have collected over the past twelve (12) months. For each category of Personal Data, these subsections also set out the source of that Personal Data and our commercial or business purpose for collecting that Personal Data. More information regarding those sources and categories are set forth below.
Categories of Personal Data We Collect
Profile or Contact Data
Examples of Personal Data Collected:
- Name
- Date of Birth
- Gender
- Sexuality, gender expression and identity
- Interests & Desires
- Phone number
- Location information if access is granted by a user
- Username
- Profile photos
- User bio (including physical characteristics or descriptions)
Source:
- You
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
- Business Partners
- Parties You Authorize, Access or Authenticate, including Other Users
Identifiers
Examples of Personal Data Collected:
- Cultural or social identifiers such as your hobbies or preferences (for example, being a skateboarder, a football fan, an environmental activist, or religious or philosophical beliefs, etc.)
Source:
- You
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
- Parties You Authorize, Access or Authenticate, including Other Users
Device/IP Data
Examples of Personal Data Collected:
- IP address
- Device ID
- Domain server
- Type of device/operating system/browser used to access the Services
- Browser plug-in types and versions
- Internet service provider
- Preferred language
Source:
- You
- Third parties, including Analytics Partners
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
Web Analytics
Examples of Personal Data Collected:
- Web page interactions
- Referring webpage/source through which you accessed the Services
- Referral source/exit pages
- Statistics associated with the interaction between device or browser and the Services
Source:
- You
- Third parties, including Analytics Partners
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
Geolocation Data
Examples of Personal Data Collected:
- IP-address-based location information
- GPS data
- Time zone setting
Source:
- You
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
- Business Partners
- Parties You Authorize, Access or Authenticate, including Other Users
Social Network Data
Examples of Personal Data Collected:
- Phone number
- User name
- IP address
- Device ID
- Name
- Profile picture
- List of friends
Source:
- You
- Third parties, including Social Networks
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
- Business Partners
- Parties You Authorize, Access or Authenticate, including Other Users
Consumer Demographic Data
Examples of Personal Data Collected:
- Age / date of birth
- Gender
- Race
- Ethnicity
- Sex life or sexual orientation
Photos, Videos and Recordings
Examples of Personal Data Collected:
- Photos, videos or recordings of you
- Photos, videos or recordings of your environment.
Source:
- You
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Advertising Partners
- Analytics Partners
- Business Partners
- Parties You Authorize, Access or Authenticate, including Other Users
Other Identifying Information that You Voluntarily Choose to Provide
Examples of Personal Data Collected:
- Identifying information in emails, letters, or texts you send us or in your survey responses
Source:
- You
Categories of Third Parties to Whom We Disclose this Personal Data:
- Service Providers
- Parties You Authorize, Access or Authenticate, including Other Users
Sensitive Personal Information
Examples of Personal Data Collected
- Race, ethnic origin, and nationality
- Precise geolocation
- The contents of your communications exchanged with other members
- Sex life
- Sexual orientation, gender expression, and identity
- Personal data concerning your health
- Religious beliefs and creed
- Philosophical beliefs
- Age (40 years or older)
- Veteran Status
Source:
- You
Categories of Third Parties to Whom we Disclose this Personal Data:
- Service Providers
- Business Partners
- Parties You Authorize, Access or Authenticate, including Other Users
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
Providing, Customizing and Improving the Services
- Creating and managing your account or profile
- Processing orders or other transactions.
- Providing you with the products, services or information you request.
- Meeting or fulfilling the reason you provided the information to us.
- Providing support and assistance for our Services.
- Communicating with you regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and security alerts.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Conducting fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the CCPA.
Marketing the Services
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioural advertising.
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about us or the Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, us or another party.
- Enforcing any agreements with you.
- Responding to claims that any posting or other content violates third-party rights.
- Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice. If you are a California resident, please note that we only use or disclose your sensitive personal information for the purposes set forth in section 7027(m) of the CCPA regulations and we do not collect or process sensitive personal information with the purpose of inferring any characteristics about California residents.
HOW WE DISCLOSE YOUR PERSONAL DATA
We disclose your Personal Data to the categories of service providers and other parties listed in this Annex 3 and in the “Who We Share Your Personal Data With” section of the Privacy Policy. Depending on the state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
DATA RETENTION
We retain your data using the criteria described in the section in the main body of this privacy policy entitled “Data Retention.”
CALIFORNIA RESIDENT RIGHTS
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].
Access
You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information:
- The categories of Personal Data that we have collected about you.
- The categories of sources from which that Personal Data was collected.
- The business or commercial purpose for collecting or selling your Personal Data.
- The categories of third parties with whom we have shared your Personal Data.
- The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business or commercial purpose, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold or shared your Personal Data, we will identify the categories of Personal Data sold or shared to each category of third- party recipient.
Deletion
You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Personal Data Sales and Personal Data Sharing
In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt-out of these sales. Also, under the CCPA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising.
As described in Annex 2, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the CCPA, sharing your data through third- party Cookies for online advertising may be considered a “sale” and/or a “sharing” of your Personal Data. In addition, under the CCPA, making your data available through third party Cookies for online advertising may be considered ”sharing” Personal Data. You can opt-out of data selling and/or sharing by following the instructions in this section.
We sell your Personal Data to, and/or share your Personal Data with, the following categories of third parties:
- Ad Networks.
- Data brokers.
- Marketing providers (including for cross-contextual behavioral advertising purposes).
We have sold the following categories of your Personal Data to the categories of third parties listed above (and we have shared such categories of Personal Data for the purposes of cross-contextual behavioral advertising):
- Profile or Contact Data
- Identifiers
- Device/IP Data
- Web Analytics
- Social Network Data
- Geolocation Data
- Consumer Demographic Data
- Photos, Videos and Recordings
- Other Identifying Information that you Voluntarily Choose to Provide
- Sensitive Personal Information
We have sold or shared the foregoing categories of Personal Data for the following business or commercial purposes:
- Improving the Services, including testing research, internal analytics and product development.
- Personalizing the Services, website content and communications based on your preferences.
- Doing fraud protection, security and debugging.
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioural advertising.
Personal Data Sales and Sharing Opt-Out and Opt-In
You have the right to opt-out of the sale or sharing of your Personal Data. You can opt-out using the following methods:
- You can complete the online form found here: [Do Not Sell or Share My Personal Information]<LINK>
- Email us at [email protected]
- By implementing the Global Privacy Control or similar control that is legally recognized by a government agency or industry standard. Please note this [does][does not] include Do Not Track Signals.
- By Phone: [. ]
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale and/or sharing of your Personal Data for at least 12 months.
Our Services are intended for users aged 18 and older and children under 18 years of age are not permitted to use our Services. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than 18, we will delete that information. Please contact us with any concerns.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
Correction
You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Portability
You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.
Deletion
You have the right to delete your Personal Data.
Opt-Out of Certain Processing Activities
- You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We Process your Personal Data for targeted advertising purposes. To opt-out of our processing of Personal Data for targeted advertising purposes, please contact us at [email protected].
- You have the right to opt-out of the sale of your Personal Data. We do not currently sell your Personal Data as defined by the VCDPA.
- You have the right to opt-out from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable.
Appealing a Denial
If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/idenx.php/file-a-complaint.
You may appeal a decision by us by using the following methods:
- Email us at: [email protected] (title must include “VCDPA Appeal”)
Exercising Your Rights Under CCPA and VCDPA
To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (if you have an account, this would mean providing your login credentials), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
- Email us at: [email protected]
- Toll free phone number: 1 (888) 537-8410
If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
OTHER STATE LAW PRIVACY RIGHTS
California Resident Rights
California’s “Shine the Light” law (Civil Code Sections 1798.83-1798.84), ensures California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected].
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Changes to this Annex
We reserve the right to amend this Annex at our discretion and at any time. When we make changes to this Annex, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.