Last updated [Date]
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with [Company Name] and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? [We do not process sensitive personal information. / We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.]
Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.
How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do I exercise my rights? The easiest way to exercise your rights is by filling out our data subject request form available here: [DSAR Form URL], or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what [Company Name] does with any information we collect? Review the notice in full below.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. CONTROLS FOR DO-NOT-TRACK FEATURES
14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
15. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you [register on the Services,] express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive Information. [We do not process sensitive information. / When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.]
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: [Cookie Notice URL].
The information we collect includes:
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
[Information collected when you use our Facebook application(s). We by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.]
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform. If you log in using Facebook, we may also request access to other permissions related to your account, such as your friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in [Countries where Server is Located]. If you are accessing our Services from outside [Countries where Server is Located], please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in [Countries where Third-Party Servers are Located], and other countries.
European Commission’s Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Data Processing Agreements that include Standard Contractual Clauses are available here: [Standard Contractual Clauses URL]. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
Binding Corporate Rules:
These include a set of Binding Corporate Rules (“BCRs”) established and implemented by [Company Name]. Our BCRs have been recognized by EEA and UK data protection authorities as providing an adequate level of protection to the personal information we process internationally. You can find a copy of our BCRs here: [BCRs URL].
[EU-US] and [Swiss-US] Privacy Shield Framework[s]
[Company Name] and the following entities and subsidiaries: [List of Entities/Subsidiaries] comply with the [EU-US] and [Swiss-US] Privacy Shield Framework[s] as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from [the European Union (EU)], [the UK], and [Switzerland] to the United States. Although Privacy Shield is no longer considered a valid transfer mechanism for the purposes of [EU] and [Swiss] data protection law, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 and opinion of the Federal Data Protection and Information Commissioner of Switzerland dated 8 September 2020, [Company Name] will continue to comply with the principles of the [EU-US] and [Swiss-US] Privacy Shield Framework[s]. To learn more about the Privacy Shield program, please visit www.privacyshield.gov. To view our certification, please visit [Privacy Shield Certification URL].
[Company Name] adheres to and complies with the Privacy Shield Principles when processing personal information from [the EU], [UK], or [Switzerland]. If we have received your personal information in the United States and subsequently transfer that information to a third party acting as our agent, and such third party agent processes your personal information in a manner inconsistent with the Privacy Shield Principles, we will remain liable unless we can prove we are not responsible for the event giving rise to the damage.
With respect to personal information received or transferred pursuant to the Privacy Shield Framework[s], [Company Name] is subject to the investigatory and enforcement powers of the US Federal Trade Commission (“FTC”). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In limited situations, [EU], [UK], and [Swiss] individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than [the period of time in which users have an account with us / [#] months past the termination of the user’s account / [#] months past the start of the idle period of the user’s account / other].
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [Email Address].