When you use the Sites, we automatically collect certain information about your
device, including information about your web browser, IP address, time zone, and
some of the cookies that are installed on your device. Additionally, as you
browse the Sites, we collect information about the individual web pages or
products that you view, what websites or search terms referred you to the Sites,
and information about how you interact with the Sites. We refer to this
automatically collected information as “Device Information.”
We collect Device Information using the following technologies:
– "Cookies" are data files that are placed on your device or computer and often
include an anonymous unique identifier.
– "Log files" track actions occurring on the Sites, and collect data including
your IP address, browser type, Internet service provider, referring/exit pages,
and date/time stamps.
– "Web beacons", "tags", and "pixels" are electronic files used to record
information about how you browse the Sites.
How do we use your personal information?
To communicate with you; to respond to your questions or inquiries and, in line
with the preferences you have shared with us, provide you with information
relating to our platforms or services.
Cookies also enable us to recognize you as a returning visitor and optimize your
browsing experience, e.g. by remembering your settings or information entered
into forms, or returning you to pages you previously visited.
If you decline or delete cookies, our Sites will still function, however your
browsing experience may be less optimized.
All data collected on our public-facing Sites will never be used to identify
individual users or to match it with further data on an individual user (this
does not apply to logged-in users within our non-public portals).
Sharing your personal information
We may share your Personal Information with third parties to help us process it
and communicate with you, as further described below. For example, we use Google
Analytics to help us understand how our users use the Sites — you can read more
about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/
Do not track
Please note that we do not alter our Sites’ data collection and use practices
when we see a Do Not Track signal from your browser.
We may provide data to other companies in our corporate group, technical service
providers (for purposes such as customer support, analytics, email delivery, or
database management), professional advisers (such as payment processors and
security, insurance, legal, and accounting service providers) inside and outside
the European Union (with Iceland, Liechtenstein and Norway, the “EEA”),
Switzerland and the UK, that require access to data in order to assist us in
providing our services. In particular, we work with reputable external data
processors in order to provide our platforms and services, including for the
purposes of storage, analysis, development, testing etc., and who are not
permitted to use any data processed on our behalf for any other purpose.
In each case we have in place safeguards that enable transfers from the EEA,
Switzerland or the UK to happen in a way that ensures that data is handled in
accordance with similar standards to those applicable in those territories.
These include: a decision from the relevant authorities indicating that the
place of receipt has adequate data protection laws; and standard contract
clauses approved by the relevant authorities for other international transfers.
A copy of these safeguards may be made available if we receive a valid
The data contained in our platforms is made available to our customers, who may
also process it in accordance with their own privacy policies and
Where data (which may include Personal Data) is provided to us by one of our
customers we enable such customer’s authorized users to access, update and
process the data provided by that customer.
In connection with a business transaction (or potential business transaction)
such as an investment, pestiture, acquisition, merger, consolidation,
reorganization or sale of assets, or in the event of bankruptcy or dissolution,
we may transfer or otherwise share some or all of our business or assets, which
may include Personal Data, with the relevant investor or acquirer, their
advisers, and where applicable any relevant regulatory authorities.
Finally, if any authority, police force or regulator validly requested data from
us, then we would normally comply with such request without having to notify
Data retention periods
We retain the data only as long as necessary for the purposes described in this
Policy. When we no longer need to use the data for such purposes (or for us to
comply with our legal or regulatory obligations), then we will either remove it
from our systems or delete all personally identifying elements so that the data
cannot be traced back to you or any other identifiable person.
Individuals located in EEA, Switzerland or the UK have various legalrights in
relation to their data including:
- To ask for access to it;
- To ask for errors in it to be corrected;
- To ask for it to be erased (the “right to be forgotten”);
- If not erased, then to ask us to restrict its processing;
- To object to its processing for specific purposes;
- To ask for a copy to take to another service provider.
California consumers also have legal rights in relation to their Personal Data
- To know what Personal Data has been collected about you;
- To ask to have it deleted;
- To opt out of sales of that Personal Data (please see the next Section);
- Not to be discriminated against for exercising any of your rights under
California privacy legislation (for example we would not deny you service,
charge you a different price, or provide you a different quality of service
Where we process any data based on consent that you have given in the past, then
you are always allowed to withdraw your consent at any time (though the
processing that took place before withdrawal will still be legal).
Please note that in some circumstances we may not be able to fully comply with a
request, e.g. where are required to retain data in order to comply with legal,
accounting, tax, or record-keeping obligations.
Where you make a request, please understand that we may need to take reasonable
steps to verify your identity or authority to make the request, and confirm the
personal information relates to you.
We are always available through the contacts at the end of this Policy to help
resolve any issues or doubts you may have in relation to processing of your
Personal Data. If you believe that your rights have not been respected at any
time then you also have a right to complain to the Data Protection Supervisory
Authority in your country to ask them for a resolution.
The Sites and our platforms and services are not intended for children and we do
not intend to process children’s data. If we learn that we have collected a
child’s personal information without the consent of the child’s parent or
guardian, we will delete it. Please always contact us with any
example, changes to our business or technology or for other operational, legal
or regulatory reasons. We recommend checking back to this page for the most
For more information about our privacy practices, if you have questions, or if
you would like to make a complaint, please contact us by e-mail at email@example.com