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Privacy Policy

Introduction

We ("we", "us", "our") take the protection of the data of users ("users" or "you") of our website and/or our mobile app (the "website" or "mobile app") very seriously and are committed to protecting the information that users provide to us in connection with the use of our website and/or our mobile app (together: "digital assets"). Furthermore, we are committed to protecting and using your data in accordance with applicable law.

This privacy policy explains our practices regarding the collection, use and disclosure of your data through the use of our digital assets (the "services") when you access the services via your devices.

Please read the privacy policy carefully and make sure you fully understand our practices regarding your data before using our services. If you have read and fully understood this policy and do not agree with our approach, you must stop using our digital assets and services. By using our services, you acknowledge the terms of this privacy policy. Continued use of the services constitutes your consent to this privacy policy and any changes thereto.

 

In this privacy policy you will learn:

  • How we collect data

  • What data we collect

  • Why we collect this data

  • Who we share the data with

  • Where the data is stored

  • How long the data is retained

  • How we protect the data

  • How we handle minors

  • Updates or changes to the privacy policy

 

What data do we collect?

Below is an overview of the data we may collect:

  • Non-personal data: Unidentified and non-identifiable information that you provide during the registration process or that is collected through the use of our services ("non-personal data"). Non-personal data does not allow conclusions to be drawn about who it was collected from. The non-personal data we collect consists primarily of technical and aggregated usage information.

  • Personal data: Individually identifiable information, i.e. all information by which you can be identified or could be identified with reasonable effort ("personal data"). The personal data we collect through our services may include information requested from time to time, such as names, email addresses, addresses, phone numbers, IP addresses and more. If we combine personal data with non-personal data, we will treat it as personal data for as long as it remains in combination.

 

How do we collect data?

The following are the main methods we use to collect data:

  • We collect data when you use our services. So when you visit our digital assets and use services, we may collect, record and store usage, sessions and related information.

  • We collect data that you provide to us directly, for example when you contact us directly via a communication channel (e.g. an email with a comment or feedback).

  • We may collect data from third-party sources as described below.

  • We collect data that you provide to us when you log in to our services via a third-party provider such as Facebook or Google.

 

Why do we collect this data?

We may use your data for the following purposes:

  • to provide and operate our services;

  • to develop, customize and improve our services;

  • to respond to your feedback, requests and wishes and to offer assistance;

  • to analyze request and usage patterns;

  • for other internal, statistical and research purposes;

  • to be able to improve our data security and fraud prevention capabilities;

  • to investigate violations and enforce our terms and policies, and to comply with applicable law, regulations or official orders;

  • to send you updates, news, promotional material and other information related to our services. For promotional emails, you can decide whether you wish to continue receiving them. If not, simply click on the unsubscribe link in these emails.

 

Who do we share this data with?

We may share your data with our service providers to operate our services (e.g. storing data via third-party hosting services, providing technical support, etc.).

We may also disclose your data under the following circumstances:

  • (i) to investigate, detect, prevent or take action against unlawful activities or other misconduct;

  • (ii) to establish or exercise our rights of defense;

  • (iii) to protect our rights, property or personal safety and the safety of our users or the public;

  • (iv) in the event of a change of control of us or one of our affiliates (by way of merger, acquisition or purchase of all (substantially) assets, etc.);

  • (v) to collect, retain and/or manage your data through authorized third-party providers (e.g. cloud service providers), to the extent appropriate for business purposes;

  • (vi) to work with third-party providers to improve your user experience.

 

For the avoidance of doubt, we may transmit, share or otherwise use non-personal data to third parties at our discretion.

Category: User has a blog or forum

Please note that our services enable social interactions (e.g. posting content, information and comments publicly and chatting with other users). We draw your attention to the fact that any content or data you provide in these areas may be read, collected and used by other people. We advise against posting or sharing information with others that you do not want to make public. If you upload content to our digital assets or otherwise make it available as part of using a service, you do so at your own risk. We cannot control the actions of other users or members of the public with access to your data or content. You acknowledge and hereby confirm that copies of your data may remain accessible on cached and archived pages even after their deletion, or after third parties have created a copy/saved your content.

When you visit or access our services, we authorize third parties to use web beacons, cookies, pixel tags, scripts and other technologies and analytics services ("tracking technologies"). These tracking technologies may enable third parties to automatically collect your data to improve the navigation experience on our digital assets, to optimize their performance and to ensure a tailored user experience, as well as for security and fraud prevention purposes.

To learn more, please read our cookie policy.

Category: User is NOT connected to an advertising service

Without your consent, we will not share your email address or other personal data with advertising companies or advertising networks.

Category: User is connected to an advertising service, a campaign manager or Facebook Ads

We may provide advertising through our services and our digital assets (including websites and applications that use our services), which may also be tailored to you, e.g. advertisements based on your recent browsing behavior on websites, devices or browsers.

To provide these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or HTML5 local storage and/or other technologies. We may also use third parties, such as network advertisers (i.e. third parties who display advertisements based on your website visits), to serve targeted advertisements. External advertising network providers, advertisers, sponsors and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or Flash cookies and/or other technologies to measure the effectiveness of their advertisements and to tailor advertising content to you. These third-party cookies and other technologies are subject to the specific privacy policy of the respective third-party provider and not to the one here.

 

Where do we store the data?

Category: Always

Non-personal data

Please note that our companies as well as our trusted partners and service providers are located around the world. For the purposes explained in this privacy policy, we store and process all non-personal data we collect in various jurisdictions.

Category: User collects personal data

Personal data

Personal data may be maintained, processed and stored in the United States, Ireland, South Korea, Taiwan, Israel and, to the extent necessary for the proper provision of our services and/or as required by law (as further explained below), in other jurisdictions.

 

How long is the data retained?

Category: Always

Please note that we retain the data we collect for as long as necessary to provide our services, to comply with our legal and contractual obligations to you, to resolve disputes and to enforce our agreements.

We may correct, supplement or delete inaccurate or incomplete data at any time at our discretion.

 

How do we protect the data?

Category: Always

The hosting service for our digital assets provides us with the online platform through which we can offer you our services. Your data may be stored via our hosting provider's data storage, databases and general applications. It stores your data on secure servers behind a firewall and it offers secure HTTPS access to most areas of its services.

Category: User accepts payments/eCom

All payment options offered by us and our hosting provider for our digital assets comply with the PCI-DSS (Payment Card Industry Data Security Standard) of the PCI Security Standards Council, which is a collaboration of brands such as Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card data (including physical, electronic and procedural measures) by our store and service providers.

Category: Always

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and will not guarantee absolute protection and security of the data you upload, publish or otherwise share with us or others.

For this reason, we ask you to set secure passwords and, where possible, not to transmit confidential information to us or others whose disclosure you believe could cause you significant or lasting harm. Since email and instant messaging are not considered secure forms of communication, we also ask you not to share confidential information via either of these communication channels.

 

How do we handle minors?

Category: User does NOT collect data from minors

The services are not intended for users who have not yet reached the legal age of majority. We will not knowingly collect data from children. If you are not yet of legal age, you should not download or use the services and should not provide us with any information.

We reserve the right to request proof of age at any time so that we can verify whether minors are using our services. In the event that we become aware that a minor is using our services, we may prohibit and block such users from accessing our services, and we may delete all data stored by us about such user. If you have reason to believe that a minor has provided data to us, please contact us as explained below.

Category: User collects data from minors

Children may use our services. However, if they wish to access certain features, they may need to provide certain information. The collection of some data (including data collected via cookies, web beacons and other similar technologies) may occur automatically. When we knowingly collect, use or disclose data collected from a child, we will do so in accordance with applicable law and will obtain parental consent. We do not make a child's participation in an online activity conditional on the child providing more contact details than is reasonably necessary for participation in that activity. We only use the data we collect in connection with the services requested by the child.

We may also use a parent's contact details to communicate about the child's activities in the services. Parents may view data we have collected from their child, prohibit us from collecting further data about their child, and request that all data we have collected be deleted from our records.

Please contact us to view, update or delete your child's data. To protect your child, we may ask you for proof of your identity. We may deny you access to the data if we believe your identity is in question. Please note that certain data cannot be deleted due to other legal obligations.

Category: Always

We only use your personal data for the purposes set out in the privacy policy and only when we are satisfied that:

  • the use of your personal data is necessary to fulfill or enter into a contract (e.g. to provide you with the services themselves or customer care or technical support);

  • the use of your personal data is necessary to comply with applicable legal or regulatory obligations, or

  • the use of your personal data is necessary to support our legitimate business interests (provided that this is done at all times in a manner that is proportionate and respects your data protection rights).

As an EU resident, you may:

  • request confirmation as to whether or not personal data relating to you is being processed, and request access to your stored personal data as well as to certain additional information;

  • request receipt of personal data you have provided to us in a structured, commonly used and machine-readable format;

  • request the rectification of your personal data stored with us;

  • request the deletion of your personal data;

  • object to the processing of your personal data by us;

  • request the restriction of the processing of your personal data, or

  • lodge a complaint with a supervisory authority.

Please note, however, that these rights are not unlimited and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal data we collect and how it is used, please contact us as indicated below.

In the course of providing the services, we may transfer data across borders to affiliated companies or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the services, you consent to the transfer of your data outside the EEA.

If you are resident in the EEA, your personal data will only be transferred to locations outside the EEA where we are satisfied that an adequate or comparable level of protection of personal data exists. We will take appropriate steps to ensure that we have adequate contractual arrangements in place with our third parties to ensure that appropriate safeguards are in place so that the risk of unlawful use, alteration, deletion, loss or theft of your personal data is minimized and that these third parties act at all times in accordance with applicable laws.

Rights under the California Consumer Privacy Act

If you use the services as a California resident, you may be entitled under the California Consumer Privacy Act ("CCPA") to request access to and deletion of your data.

To exercise your right to access and deletion of your data, please see below on how to contact us.

Category: Website does not sell its users' data

We do not sell users' personal data for the intentions and purposes of the CCPA.

Category: Websites with a blog or forum

Users of the services who are residents of California and under the age of 18 may request and obtain the deletion of content they have posted by emailing the address provided in the "Contact" section below. These requests must all be labeled "California Removal Request". All requests must include a description of the content you wish to have deleted as well as sufficient information to enable us to locate the material. We do not accept notices that are not labeled or not properly submitted, and we may not be able to respond if you do not provide sufficient information. Please note that your request does not ensure that the material will be completely or comprehensively deleted. Material you have posted may, for example, be republished or reposted by other users or third parties.

 

Updates or changes to the privacy policy

Category: Always

We may revise this privacy policy from time to time at our sole discretion, the version published on the website is always current (see "as of" indication). We ask you to review this privacy policy regularly for changes. For material changes, we will post a notice on our website. If you continue to use the services after notification of changes to our website, this will be deemed your acknowledgment and consent to the changes to the privacy policy and your agreement to be bound by the terms of those changes.

 

Contact

Category: Always

If you have general questions about the services or the data we collect about you and how it is used, please contact us at:

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