Privacy Policy and Notice at Collection

Effective Date: 02.03.2023

The operator of this website and its affiliates (referred to herein as “Distributor” or “we”) collect information about you when you use this website and other websites, applications or other online services that we operate (collectively, the “Services”). 

BY USING THE SERVICES, YOU CONSENT TO THE PROCESSING OF INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY AND NOTICE AT COLLECTION. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

1.     SCOPE OF THIS PRIVACY POLICY AND NOTICE AT COLLECTION

This Privacy Policy and Notice at Collection (collectively “Notice”) describes the information that Distributor collects (directly or indirectly) and why we collect it, what we do with the information we collect and how you can manage your information through the Services. This Notice applies to you when you use our Services or communicate with us offline, such as by telephone. You may have additional rights depending on your US state of residence. For more information on your rights under state laws, including the California Consumer Privacy Act (“CCPA”), please review the “State Privacy Rights” section of this Notice. You can download a printable copy of this Notice here.

If a particular Service has its own privacy policy or links to a different privacy policy, then that privacy policy -- not this Notice -- applies. This Notice also does not apply to any website or service that does not display or link to this Notice.

Our agreements with certain customers may contain provisions about the collection, use, storage and disposal of personal information collected through the Services and offline. If a provision of a customer agreement conflicts or otherwise is inconsistent with a provision of this Notice, then such provision of the customer agreement will prevail but solely to the extent of the conflict or inconsistency.

If you have not done so already, please also review the Terms of Service.

NOTICE AT COLLECTION

2.     CATEGORIES OF INFORMATION WE COLLECT

We may collect the personal information categories listed below. the categories of personal information the business has collected about consumers in the preceding 12 months.

• Identifiers. Such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Such as name, address, or telephone number. Some personal information included in this category may overlap with other categories.

• Commercial information. Such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Internet or other similar network activity. Such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

3.     PURPOSE OF COLLECTION AND USE

We collect personal information to support our business operations. Most commonly, we will use your personal information in the following circumstances.

·         Where we need to perform the contract we are about to enter into or have entered into with you.

·         Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.

·         Where we need to comply with a legal or regulatory obligation.

We do not sell or share personal information. In the event that we do sell or share any personal information, we will update this Notice to list the categories of consumers’ personal information sold or shared.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We use information collected for the following purposes based on our legitimate interests:

·         To communicate with you;

·         To administer and protect our business and the Services including troubleshooting, data analysis, security, testing, system maintenance, support, reporting, technical functionality, hosting of data, and in the context of a business reorganization or group restructuring exercise;

·         To prevent and investigate fraud and other misuses of the Services;

·         To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

·         To use data analytics to improve our website, products/Services, marketing, client relationships and experiences; or

·         To make suggestions and recommendations to you about products or Services that may be of interest to you.

·         To evaluate you for employment or an internship.

We also use your personal information when necessary for the performance of a contract in the following contexts:

·         To process your payments, orders, and transactions including:

o    Manage payments, fees and charges

o    Collect and recover money owed to us;

·         To set up and maintain your account with us;

·         To manage our relationship with you which will include:

o    Notifying you about changes to our terms or privacy policy

o    Asking you to leave a review or take a survey

o    Responding to your questions and inquiries

We may also use your personal information when necessary to comply with legal obligations.

For the purposes of this Notice, to “process” personal information means to perform any operation on personal information, whether or not by automated means, such as collecting, recording, organizing, storing, adapting, using, disclosing, combining, erasing or destroying.

Where we need to collect personal information by law, or under the terms of a contract between us and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or Services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case.

4.     INFORMATION RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Notice, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

(a)   the length of time we have an ongoing relationship with you and provide Services to you (e.g., for as long as you have an account with us or keep using the Services);

(b)   whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them);

(c)   whether retention is advisable considering our legal position (e.g., for statutes of limitations, litigation or regulatory investigations).

5.     HOW WE COLLECT INFORMATION

User Provided Information: We collect information that you provide directly to us, such as when you create or modify your account, request customer support or otherwise communicate with us. This information includes (a) your name, postal address, email address and telephone number; (b) username, password and other registration information; (c) transaction-related information, such as when you download or use applications from us or register for the Services; (d) information you provide us when you contact us for help; and (e) other information you choose to provide and enter using the Services.

If you make payments through the Services we may also collect information required for payment processing, such as credit or payment card number, expiration date, cvv number, billing address, company name, and other information required for payment processing (“Payment Information”).

We use a third-party payment processors, currently Stripe, PromoPayment, Authorize.net, and Paypal, (“Payment Processors”) to assist in securely processing your Payment Information. If you pay with a credit card the Payment Information that you provide through the Services is encrypted and transmitted directly to one of the Payment Processors. We do not store your Payment Information and do not control and are not responsible for the Payment Processors or its collection or use of your information. You may find out more about how the Payment Processors store and use your Payment Information by accessing the Payment Processor’s privacy policy.

If you choose to use PayPal to make purchases through the Site, you will be directed to the PayPal website and provide your payment information directly to PayPal. PayPal’s privacy policy applies to the information you provide on the PayPal website.

Automatically Collected Information: The Services automatically collect information about how you use the Services, such as (i) your mobile device or computer type, including your system and application software; (ii) the type of mobile device or computer you use, the pages and screens you view and how long you viewed them; (iii) your mobile device’s unique device ID; (iv) the IP address of your computer or mobile device; (v) your operating system, traffic data, logs and other communication data; and (vi) metadata and other information associated with other files stored on your device (e.g., photographs, audio and video clips and personal contacts). Some of this automatically collected information is personal information.

Information Collected from Third-Party Sources: We may combine information we receive from other sources with information we collect through the Services. For example, (A) if you engage with a third-party site application whose API we use (or who uses our API), we may receive information about you or your connections from such site or application; or (B) if you are referred to us by one of our referral partners, we receive information about you from such referral partner.

6.     COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

The Services may use cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Technology”).

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (i.e., the internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services. A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Data Collection Technology helps us improve your experience of the Services by, for example, storing your password, measuring the success of marketing campaigns, compiling statistics related to use of the Services and helping us analyze technical and navigational information about the Services in order to detect and prevent fraud. 

We may use other Data Collection Technology to collect information from the computer or device that you use to access the Services, such as your operating system type, browser type, domain and other system settings,