- INFORMATION RECEIVED, COLLECTED, AND STORED BY THE COMPANY
During your use of our Services, we collect and process some or all of the following categories of information. The type of data we gather will be determined on the circumstances and the Service you are using.
In general, the Company collects two types of information on users: (a) data submitted by users and (b) data automatically tracked while navigating. (c) data gathered from any other source (referred to collectively as “Information”).
- (a). User-supplied information
- Registration Details:
Basic contact information supplied by you on our Website may include, but is not limited to, your name, cellphone number, address, e-mail address, date of birth, demographical information, gender, interests, preferences, place of employment, position, and country. Personal Information may be collected by the Company when you register on the Website, subscribe to our Services, or request additional information. It can also include information that you have volunteered but that we have not requested, such as information provided during interactions with our online Services, such as online forums, in response to a survey, while requesting certain Services or products, or to enter a sweepstakes, contest, or other promotion.
When you register with other accounts such as Facebook, Twitter, or Gmail, we will retrieve information from those accounts in order to continue interacting with you and providing the Services. The Company may use your information to send you information, special offers, and promotions by e-mail or other means
If you opt not to give personal information on the Website, the Company may be unable to provide you with access to certain sites/content/apps/services/features. We will make every reasonable attempt to inform you of this when you open your account. In any case, we will not be liable or responsible if certain services are denied to you due to your failure to provide the required personal information.
- Data from a subscription or paid service:
Any subscription or paid Service can be purchased using a credit card, e-wallet, or other electronic payment mechanism. We or our payment system provider may collect your purchase, address, or billing information, such as your credit card number and expiration date, when you choose any subscription or paid Service (“Payment Information”). When you order through an in-app purchase option, however, such platform providers manage the transaction. Payment information is often submitted directly by users through the Website to the PCI/DSS-compliant payment processing service to whom the Company subscribes, and the Company does not handle or store the Payment Information itself, save as noted herein.
Unless cancelled, subscriptions or purchased Services may be automatically renewed. You may cancel your subscription before the end of the subscription period if you do not want it to renew automatically.
This Payment Information is used to provide you with the Services you’ve requested, to administer your account, to interact with you, and to enforce any Website terms of service or agreements. We only utilise the payment information we obtain from you to complete your order.
- (b) Automatically tracked information while navigating:
We automatically record information about your use of our Services, your interactions with our advertisements and emails, as well as information about the device you are using and your internet connection when you use them. This is accomplished in the following ways:
The Company and the parties with whom we work may use the information collected for a variety of purposes, either on behalf of the Company or for the other parties’ own purposes, such as research, analysis, better serving visitors to the Website (such as by providing customised content or presenting online advertising on the Website or other websites tailored to your interests, as described further below), and compiling aggregate and anonymous information about usage of the Website. These uses will not be feasible if you have deleted and disabled cookies to the degree that they are based on cookie information. This is anonymous statistics information on our users’ browsing activities and tendencies.
- Information from the Log File:
When you access the Website / Service, we automatically collect limited information about your computer’s Internet connection, cellphone number, and so on. Your browser automatically sends us information such as the name of your computer, operating system, browser type and version, IP address, CPU speed, and connection speed.
We may also collect log information from your device, such as your location, IP address, device name, serial number, or other unique identifier (e.g. UDiD on your iOS device). If you use a mobile or other device to use the Services, we may collect a unique device identifier, geo-location data, or other transactional information for that device.
- Clear GIFs:
We may utilise clear GIFs in HTML-based emails sent to our users in addition to web beacons to track which emails are opened. We use this information to, among other things, measure traffic on the Website/Service, improve the quality, functionality, and interactivity of the Website/Service, and educate advertising about the geographic locations from which our visitors originate.
- c) Information gathered from other sources:
- Other Sources of Information: Information on demographics and purchases
In order to provide you with more tailored communications and promotions, we may consult different sources of demographic and other data. On our website, we utilise analytics technologies to track user behaviour.
These features have been enabled to help us understand our visitors’ demographics and interests by supporting display advertising. The reports are anonymous, and they cannot be linked to any personally identifying information you have provided with us.
- Information on advertisements and purchases:
In order to help display advertisements that you see on the Website or on other websites, the Company or third-party advertisers or their advertising servers may place or recognise unique cookies on your computer or use other electronic tools.
Information about your visits to and activity on the Website and other websites, as well as an IP address, the number of times you’ve viewed an advertisement, and other similar usage data, is used alone or in combination with other data to display advertisements on your device screen that may be of particular interest to you. To manage and optimise our online advertising and product performance, we may employ web beacons provided by third-party advertising partners. When a browser visits this Website, web beacons allow us to recognise that browser’s cookie and discover which banner ads brought users to our Website. This policy does not cover the use and collecting of your information by these third-party service providers, as well as third-party advertisers and their advertising servers.
COMPANY USE OF INFORMATION
We use information about you for the following objectives in order to further our legitimate business interests:
- To provide you with Services, including associated functionalities, whether we or our designated representatives and/or business partners provide them to you or to parties you designate, and all matters ancillary thereto, including to carry out obligations under any contracts we may have entered into. The legal foundation for such processing is the fulfilment of our contract with you
- When you subscribe to, purchase, and/or acquire Services from any of our Website, we will verify and process your payment. The legal foundation for such processing is the fulfilment of our contract with you
- To verify and record your personal information in order to authenticate you so that we know it is you and not someone else, which includes comparing it to information from other sources and communicating with you using the information. The legal foundation for such processing is the fulfilment of our contract with you.
- To conduct market research and statistical analysis of Website users, including the number of users, frequency of use, and profile of users, and to use the results of such analysis in our business plans, product and service enhancements, targeted advertisements, and to convey such information in broad terms (but not in relation to specific individuals) to third parties who have or intend to have business dealings with us. The legal basis for such processing is legitimate business interests, as well as the legitimate interest in analysing and improving the Services.
- To provide you information, promotions, and updates about our Services and those of third-party organisations we select, including marketing and advertising materials. We will only do so if we consider our Services may be of interest to you and you have given your agreement to receive such information. We rely on legitimate business interests as the legal basis for this processing to promote our Services to you.
- To prevent fraud and other potentially illegal actions (such as copyright infringement), as well as to block disruptive users and protect our users’ safety. Our legitimate business interests, which include the adequate protection of our business against risks and threats, form the legal basis for this approach
- To ensure that our terms of service are followed. The protection and assertion of our legal rights, as well as the legal rights of others, is the legal foundation for this processing
In any case, if you do not want us to market or promote our products and Services to you, please either
- check the relevant box on the form on which we collect your Information (for example, the registration form).
- unsubscribe from our electronic communications using the method indicated in the relevant communication.
Sensitive Personal Information
We ask that you not send us, and that you not disclose, sensitive personal information on or through the Services or otherwise to us, unless we specifically request it (e.g., information related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, national identification numbers, social security numbers, criminal background, trade union membership, or administrative or criminal proceedings and sanctions).
PERSONAL INFORMATION AND OTHER INFORMATION DISCLOSURE
In the following restricted circumstances, the Company discloses your Information with any third party without first obtaining the User’s consent:
(a) Information shared with affiliates and group companies
For the purpose of processing Information on its behalf, the Company may share Information with its employees, agents, officers, group companies, the employees, agents, and officers of such group businesses, and our affiliates (including associated websites under common ownership or management).
(b) Information shared with Sponsors and Third Parties
- The Company may share anonymous and aggregate information about our Website users with other third parties, such as your use of the Website or other websites, and the Services provided on the Website or other websites, but only to help us develop content, services, and advertising that we hope you will find interesting. Your Information may also be shared with a sponsor or other third party (“Third-Party Provider”) for Site-related services such as database management, maintenance, analytics, marketing, data processing, and email and text message distribution. These third parties only have access to your information if they are working on our behalf.
- To assist sponsors, the Company may provide Information. If you use some Website features (for example, sharing interesting news stories), please be aware that any Information you or others willingly disclose using these services becomes visible to the public and/or other users whom you have selected.
c) Data exchanged through third-party social buttons, widgets, and other embedded material
Please be aware that companies may track your behaviour without your knowledge or consent, using cookies or similar technology. If you’re concerned about this, log out of their services before utilising ours.
Furthermore, when you access or use the Website or Services, we use third-party advertising businesses to show ads. These organisations may use information about your visits or use of websites, mobile applications, or services (but not your name, address, email address, or telephone number) to target advertisements for goods and services that you might be interested in.
(d) Information Disseminated to Third Parties
If we believe in good faith that such disclosure is essential, the Company may additionally release your personal and other information to unaffiliated third parties:
(i) to establish or exercise our legal rights, or to defend against legal claims;
(ii) to protect the interests, rights, safety, or property of the Company or others;
(iii) to enforce any terms of service on the Website;
(iv) to investigate, prevent, or respond to a subpoena, court order, search warrants, notification/notice/order from appropriate governmental authority, judicial proceedings, other legal process, or other law enforcement measures;
(v) to provide you and other users of the Website with the Services or products you and/or other users have requested, as well as to perform other activities related to such Services and products, such as billing and collection;
(vi) to provide you with special offers or promotions from the Company that may be of interest to you; or (vii) to properly operate the Company’s systems.
(f) Sale or Transfer of All or Part of the Company’s Business
If the Company sells all or part of its business, sells or transfers its assets, or is otherwise involved in a merger or transfer of all or a major portion of its business, the Company may share your information with the person or parties involved in the transaction.
(g) In addition to the scenarios listed above, we may share Information about you for any other purpose disclosed to you at the time of collection or with your consent
(h) Some General Disclosure Exceptions
The Company is not responsible for the collection, further use, or disclosure of your information by Third-Party Providers or any third parties. Rather, the privacy rules of Third-Party Providers govern such data collection, use, and/or disclosure.
- Any personally identifiable information you give will not be considered sensitive if it is widely available and/or accessible in the public domain, such as any comments, messages, blogs, or scribbles on social media platforms such as Facebook, Twitter, and so on.
The aforementioned exclusions are not exhaustive and will contain both legal and non-legal exceptions
PERSONAL INFORMATION SECURITY
Any personal data you disclose to Company is stored on secure servers with restricted access. The Company takes reasonable administrative, technical, personnel, and physical means to (a) protect personal information from loss, theft, unauthorised use or access, disclosure, or modification; and (b) maintain the personal information’s integrity.
We also have protocols in place to deal with any data security breach that may occur. Where we are legally required to do so, we shall notify you and any applicable regulators of a suspected data security breach.
No security system, however, is impregnable, no matter how effective it is. We cannot guarantee the security of our database or that information you provide will not be intercepted while being communicated to us over the Internet; any transmission is at your own risk. Any information you put in a posting to the discussion areas is, of course, accessible to anybody with internet access.
The Website may contain links to and from the websites of our partner networks, advertisers, and affiliates from time to time. If you click on a link to one of these websites, please be aware that these websites have their own privacy policies and terms of service, for which we take no responsibility or obligation. Please review these rules before submitting any personal data to these websites.
Remember that copies of some Information from your account may be visible even after you cancel your account in some instances, such as where you have shared information with social media or other services and such Information is outside the Company’s control.
Furthermore, please contact us promptly if you have cause to believe that your engagement with us is no longer safe (for example, if you believe the security of your account has been compromised).
PERSONAL INFORMATION TRANSFER TO OTHER COUNTRIES
RIGHTS AT YOUR DISPOSITION
You have numerous vital rights that are completely free. In a nutshell, you have the right to:
- Access and update your information: When you use the Services or the Website, we make good faith efforts to provide you with access to your Information as and when you request it. Furthermore, if your Information changes, you can update it by visiting the appropriate page of the Website or contacting us. Please contact us if you have any queries about how we use the information we collect about you. We will make every effort to update your information within 14 working days of receiving new or updated information, in order to guarantee that the information remains accurate. We keep your information as accurate and up to date as possible.
- Require us to fix any errors in your information: In this situation, we will ensure that any erroneous or defective information or data is corrected or modified as soon as possible, subject to any legal or business requirements that such information be preserved.
- Require the deletion of your information in specific circumstances.
- Require us to limit or object to the processing of personal information in specified circumstances at any time.
- Have the right to receive and transmit the personal information about you that you have submitted to us in a structured, frequently used, and machine-readable manner.
- Object to automated decisions that have legal consequences for you or have a similarly significant impact on you.
- Oppose our continued processing of your personal information in certain other circumstances.
- In specific cases, restrict our processing of your personal information.
Before processing such requests, we require individual users to identify themselves and the information that needs to be accessed, updated, or removed, as well as to specify any other restrictions you want to place on our use of your personal information. If you wish to exercise any of these rights, please contact us through email, phone, or letter, and provide us with sufficient information to identify you [(e.g., account number, username, registration details)], as well as the Information to which your request refers.
Before we can complete your request, we may need to verify your identity. We will do our best to fulfil your request as quickly as possible. Please keep in mind that we frequently need to maintain certain data for record-keeping purposes and/or to finish any transactions you started before requesting a correction or deletion. Furthermore, due to the way we manage certain services, residual copies of your Information may take some time to be purged from our live servers and may persist in our backup systems after you delete your Information. Furthermore, for legal, security, or other reasons, we may not allow you to review certain data.
The duration of our ongoing engagement with you and provision of Services to you (for example, for as long as you keep using the Services)
Is there a legal requirement to which we must adhere? (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
Is retention necessary in light of our legal situation? (such as, for statutes of limitations, litigation or regulatory investigations)
CHILDREN WHO USE OUR SERVICES
We do not knowingly collect or store personal information from children under the age of 13 unless otherwise indicated. We ask that you do not give us any information about yourself or others if you are under the age of 13. Before using our Services, please seek advice from your parent or guardian.
If you are the parent or guardian of a child under the age of 16, and you learn that your child has provided us with information without your permission, please contact us at the address listed below. We will promptly remove such information from our files.
The older kids If you are under the age of 18, we may also ask the agreement of your parent or guardian, depending on the service.