Effective Date: April 30, 2014
As described in this Policy, we may disclose your personal data with our affiliated companies and, under certain circumstances, with third parties that provide services on our behalf or with whom we have partnered to offer a particular product or service. This Policy describes the personal data we collect about you, why we collect it, how we use it and under what circumstances we disclose it to third parties. This Policy also describes the decisions you can make about how you provide your personal data to us.
If this Policy changes in the future, we will post an updated version on our website or Services. You can tell if this Policy has changed by checking the revision date that appears at the top. When we change the Policy in a material way, we will provide notice via email, regular mail, or posting notices or links to notices on our website.
- Information We Collect
- Using Information We Collect
- Sharing Information We Collect
- Managing your Information
- Our use of beacons
- Links to Other Sites
- Retention of information
- Privacy Rights / Questions or Comments
Information We Collect
We process and store the personal data that we collect from you or you have voluntarily submitted in electronic or any other form of communication subject to the applicable data protection laws. To register to use our website or Services, you need to submit certain personal data which includes your name and email addresses.
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use the Services. If you believe that we may have any information about a child under 13, please contact us from our inquiry page.
The following describes which information is collected and/or stored by us:
1. Usage data
- When you make use of websites or Services operated by us, we automatically save the domain name and/or IP address of the computer or device used to contact us; the date as well as the length of the visit at websites and Services operated by us, for instance through cookies; as well as pages accessed by you on our operated websites and Services as well as the browser used.
2. Email address
- We store the email addresses you have submitted to us in electronic or any other form of communication.
3. Information resulting from communication with us
- When you submit a ticket or email to our customer support, we collect and save the history of communication with you as well as any personal data submitted by you in the course of the communication (for example the email address), in order to answer your inquiry as best we can. We do not share this information with third parties.
4. Other, voluntarily submitted information about you
- We always strive to improve our offerings and services as well as to adapt them to our users. Therefore, you can submit additional personal data to us as part of the use of our offers and services or in the course of direct communication with us, such as name, address, age, gender, interests and, if applicable, payment data (if you process a payment via our website or application). You can also allow us to collect and record your usage behavior on partner websites.
Using Information We Collect
To provide you with the best possible customer experience, your personal data is collected, used and/or disclosed, always in accordance with the applicable data protection laws, for the following purposes:
1. Usage data and other personal data
- Provision and Optimization of the Services. We collect, process, and store your personal data, in so far as we see legitimate legal or business purposes for it. In other words: we collect, process, and store your data to offer you better services. We can, for instance, not only use the personal data collected for direct processing of the agreement concluded with you (i.e. use of the Services, creation of invoices, use of customer support), but we can also use it to identify malfunctions and/or misuse of our websites and the Services, to communicate with you about our and our affiliated companies’ products, services and promotions, and to deliver content that aligns with your interest, etc.
- Prevention and combat of abuse. We collect and store your personal data on the use of our websites and Services, such as your activity on our websites and the Services. These include the monitoring of behavior patterns and checking for manipulations that can be useful in detecting misuse or improper activity by you. We use special software, for example, to detect the use of illicit scripts and identify the IP address as well as other data in regard to your usage behavior. If we determine that you violate your contractual obligations, for instance by using illicit scripts, we explicitly reserve the right to bring your data together with other data collected by us to prove the violation. We will then possibly take additional measures against you concerned to restore normal operation.
- Billing of services. We may entrust your personal data to the service provider responsible for payment processing insofar as this is required for billing. We also may entrust your personal data to third parties authorized to collect outstanding balances, insofar as this information is required or useful to collect the balance. We will inform you of the name of the third party. If we cooperate with third parties for these services, we will obligate them to observe applicable data protection laws.
- Our Marketing activities etc. We may use personal data stored by and from you to analyze information stored about you, make statistical information, distribute advertisements, and improve our services without being able to attribute it to a specific person.
2. Email address
We may use the email addresses acquired through an offer from us or received directly from you, to send you newsletters and information on our or our affiliated companies’ offers. You can withdraw this consent in writing at any time via email. You will have the opportunity in every information and newsletter sent by us to unsubscribe or send a cancellation notice.
3. Miscellaneous, voluntarily submitted information
Other than those above, if you voluntarily share personal data on request by us, then we will use this information with your consent for the purposes of the provision and optimization of our services such as the Services, and our marketing activities etc.
Sharing Information We Collect
Your personal data held by us will be kept confidential, but we may share your personal data with the following parties in the following ways, subject to the applicable data protection laws:
- We may entrust your personal data to our service providers who manage our customer information and perform services on our behalf, such as fulfilling promotions, sending communications to our users, conducting surveys, etc. We do not authorize any of these service providers to make any other use or disclosure of your personal data.
- We may share your personal data when we partner with another company in a joint marketing program to offer or provide products, services, contests, or promotions to our users. Except for sharing this personal data with a joint marketing partner, we do not disclose sell or lease your personal data to any third party to use for marketing their products and/or services.
- We may disclose your personal data without your consent if the disclosure is allowed by any applicable laws, including, in case of complying with legal process (such as a court order, subpoena, search warrant etc.) or other legal requirements of any government authority.
- We may transmit your personal data to advertisers only when the user redeems a promotional offer of such a partner company participates in a survey and the information is required for processing or for participation in the survey.
- Except as otherwise provided in this Policy, Personal and pseudonymized user data are used solely by us and not shared with third parties. Third parties receive information about user behavior only without being able to attribute it to a specific person.
- If we should ever file for bankruptcy or merge with another company, or if we should decide to buy, sell or reorganize some part or all of its business, we may be required to disclose your personal data to prospective or actual purchasers or receive personal data from sellers. It is our practice to seek appropriate protection for information disclosed or received in these types of transactions.
- Third parties do not collect personally identifiable information about your online activities over time and across different online services when you use the Services.
- Our website and the Services we provide do not respond to or recognize web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of their personally identifiable information about users’ online activities over time and across third party sites or apps because the Services does not collect such information.
Managing your Information
We want to communicate with you only if you want to hear from us. We provide a choice in communication for you so you can receive information from us at your discretion. Subject to applicable data protection laws, you shall have on giving reasonable written notice to us a right to:
- Request for access to your personal data; and Correct any error or omission in your personal data.
Please contact us from our inquiry page if you:
- Wish to request access to or correct your personal data or Have any questions.
- We also communicate with you by promotional email. If you would like to be removed from our promotional email please write to us from our inquiry page. We will process your request within 30 business days.
We will protect your personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorized access, use or disclosure to ensure that you will have a safe online experience. We have in place certain physical, electronic, contractual, and managerial safeguards to protect the security and privacy of your personal data.
When you enter your personal data on our websites or services, we use Secure Sockets Layer (SSL) technology to protect your information as it is transmitted to us. If you see an unbroken key or a closed lock (depending upon your browser), then SSL is active. To double-check for security, look at the URL or Location line of your browser. If you have accessed a secure server, the first characters of the address in that line should generally change from "http" to "https."
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Services or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. We may post a notice on our website if a security breach occurs. If this happens, you will need a web browser enabling you to view the website. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us from our inquiry page.
Identity thieves sometimes send fraudulent email messages to trick users into divulging personal or financial data (a practice known as "phishing"). "Phishing" is a scam designed to steal your personal data. If you receive an email that looks like it is from us asking you for your personal data, do not respond. We will never request your password, user name, credit card information or other personal data through email. If you have received or entered personal data in response to a suspicious email, pop-up or phony website claiming to be affiliated with us, please email us from our inquiry page immediately.
We regularly use browser cookies for tracking. A cookie is a small text file that is placed on your hard disk by a website. Cookies are uniquely assigned to you, and can only be read by a website or web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.
- Recognize you when you return to our website;
- Keep track of the applications which you register or upload or store on our website and remember what applications are in your account;
- Process your purchase order on our website and enable you to use PayPal Checkout, if you have created an account at our website;
- and/or study and review how our guest's navigate through our website and which services they request in site searches.
2. Our use of Web Beacons
We also employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages or emails and are about the size of the period at the end of this sentence. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon.
3. Links to Other Sites
Occasionally we provide links on our website or Services to other sites we think you will enjoy. These sites operate independently of us. For the best online experience, we strongly encourage you to review these policies at any site you visit. We are not responsible for the content or practices of any linked websites or services which are provided solely for the convenience and information of our visitors.
Retention of Information
We shall cease to retain your personal data or remove the means by which the personal data can be associated with you as soon as it is reasonable for us to assume that the purpose for which your personal data was collected is no longer served by the retention of the personal data and retention is no longer necessary for our legal or business purposes.
We will treat any feedback, emails or suggestions you provide to us as non-confidential and non-proprietary.
Privacy Rights / Questions or Comments
Except as otherwise provided in this Policy, unless we have your consent or are required or permitted by applicable laws, we will not disclose your personal data to third parties. We will endeavour to ensure that our employees, officers, agents, consultants and contractors who are involved in the collection, use and/or disclosure of your personal data will comply with all applicable laws and observe and adhere to the terms of this Policy.
If you have any questions or comments, please feel free to contact us from our Contact Us page.