To view our previous Privacy Policy, click here.
1. Introduction
Please read the following policy to understand how your personal information will be treated as you make full use of our Website. When we talk about our Website or our Service, we are referring to this website, any corresponding mobile application and any services provided by us through such website and/or application. When we talk about "we", "our" or "us" in this policy, we are referring to , the company that provides the Website and Service. If you have any questions, concerns or complaints related to this Privacy Policy or our processing of your personal information, please email us here: [email protected]. This email address is monitored on a regular basis and we aim to respond to your query as soon as possible.
The Privacy Policy has three main purposes:
All the information we collect is related to providing our Website or Service. By agreeing to our Privacy Policy, you give us the right to collect your information as detailed in this Privacy Policy and use it for the purposes described in this Privacy Policy. IF YOU DON'T AGREE WITH THE TERMS OF THIS PRIVACY POLICY, THEN PLEASE DON'T USE THE WEBSITE OR SERVICE.
2. Information we collect
The information we collect can be divided into the following broad categories:
More specifically, we may collect and store the following information relating to you:
2.1 Anonymous data
When you visit our Website, we collect some basic information that does not identify individual users. This includes which pages are visited and any feedback from our visitors. We then aggregate this information with other pieces of information to improve our Website and make your experience on the Website as valuable and efficient as possible. We may also collect and accumulate anonymous data that will help us understand and analyze the online experience of our Website users. For instance, we may accumulate visitor data relating to referring domain names, the type of browsers used, operating system software, screen resolutions, color capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords and JavaScript enablement.
2.2 Direct Interactions
We collect information from you when you voluntarily submit information directly to us or via our Website. For members, this refers to personal data you provide when, for example, you create an account, complete a profile, or by corresponding with us via phone, email or live chat. This personal information may include name, age, address, phone and email, as necessary to set up your account. If you connect to the Website using credentials from a third-party application (e.g., Facebook), you authorize us to collect your authentication information, such as your username and encrypted access credentials. We may also collect other information available on or through your third-party application account, including, for example, your name, profile picture, country, hometown, email address, date of birth, gender, friends’ names and profile pictures, and networks.
You may decide to provide us with another person's contact information so that person may be invited to join our Service or so that we may facilitate your communication with other people through the Service (such as when you upload an address book or a contact list). You may also provide us with another person's contact information for purposes of delivering information through social networking applications. We store the information that you provide so that the respondents may be added to your network, and also to send reminders of the invitations. All invitees are provided with the option not to receive further invitations from us.
In addition to the information we may collect upon your initial registration, we may ask you for personal information at other times. We will not share that information in a manner that identifies you as an individual with any other entity unless we have your permission.
2.3 Information submitted by you for inclusion on the Website
Please remember that if you post any of your personal information in public areas of the Website, such as in online forums or chat rooms, such information may be collected and used by others over whom we have no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of the Website. You should take care to not use personal information in your screen name or other information that might be publicly available to other users.
2.4 Tracking technologies
We use "cookies" and similar tracking technologies (as described in Section 5 below and in our Cookie Policy) to track your activities on our Website, and may also receive data about you if you visit other websites employing our cookies. When we send you emails that include a link to the Website, that link may contain an alphanumeric identifier that allows us to identify the person to whom we sent the message so that we can personalize our content for that individual.
2.5 Automated technologies or interactions
As you interact with our Website, we may automatically collect technical and usage data about your device, browsing actions and patterns. For example, we collect information which may include your IP address, browser type, your location, language preferences, device information and access times. While an IP address does not identify an individual by name, it may, with the cooperation of the ISP, be used to locate and identify an individual. Your IP address can reveal what geographic area you are connecting from, or which ISP you are using. Finally, other websites you visit have IP addresses, and we may collect the IP addresses of those websites and their pages. We also collect IP addresses for system administration and to report aggregate information to any sponsors. We may also receive information from our web logs, which automatically record anything a web server sees, which may include email addresses you enter into a form or pages viewed by a user at a particular IP address. We collect this personal data by using cookies, pixel tags and other similar tracking technologies. The sole purpose of passively collecting your information is to improve your experience when using our Website.
2.6 Payment data
If you purchase a subscription to our Service or make other purchases through the Website, your credit or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by us and/or the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to process your purchase. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, and your card’s type, expiration date, and certain digits of your card number.
2.7 Promotions & surveys
From time to time, we may offer you the opportunity to participate in promotions such as sweepstakes, contests, offers, and/or surveys (“Special Promotions”) through the Service. A Special Promotion may be governed by a privacy policy and/or terms and conditions that are additional to, or separate from, this Privacy Policy and our Terms of Use. If the provisions of the Special Promotion’s privacy policy or terms and conditions conflict with this Privacy Policy or our Terms of Use, those additional or separate provisions shall prevail. If you participate in a Special Promotion, we may ask you for certain information in addition to what is stated in this Privacy Policy, including personal information. That additional information may be combined with other account information and may be used and shared as described in this Privacy Policy or in the Special Promotion.
2.8 Information received from our service providers and partners
We may also receive information about you from our service providers and partners, which we use to personalize our Service, to measure ad quality and responses to ads, to display ads that are more likely to be relevant to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you.
3. How we use the information we collect
We have set out below, in a table format, a description of all the ways we process your personal data, and the legal basis we rely on to do so.
Purpose/Activity | Type of Data | Source | Legal Basis |
---|---|---|---|
To allow you to visit the Website |
Technical Data
Usage Data |
Directly from you
From our service providers |
Consent |
To allow you to create an account |
Identity Data
Usage Data |
Directly from you
From our service providers |
Consent |
To register you as a paid member and process renewal of your membership |
Financial Data
Identity Data |
Directly from you | Consent |
To manage our relationship with you. For example general enquiries such as how the Website works, complaints and payment queries | Any data you choose to share with us or request us to view | Directly from you | Consent |
To administer and protect the Website (including troubleshooting, fraud prevention, spam prevention, security incident prevention and correction, data analysis, testing, system maintenance, support, reporting and hosting of data), operate the Website (including notifying you of any changes), optimize your user experience, and send you service and support messages such as updates, patches and security alerts |
Financial Data
Identity Data Technical Data Usage Data |
Directly from you
From our service providers |
Consent |
To send you promotional messages, marketing, advertising and other such information we think may be of interest to you, either directly or through one of our partners; you may opt out from receiving certain messages, as described in Section 7 |
Financial Data
Identity Data Technical Data Usage Data |
Directly from you
From our service providers |
Consent |
To enable you to partake in a prize draw, competition, referral scheme, rewards program, promotional activities, events, complete a survey or invite you to participate in Website testing |
Financial Data
Identity Data Technical Data |
Directly from you | Consent |
To analyze your use of the Website and deliver relevant website content and third-party advertisements, for example by providing customized, personalized, or localized content, recommendations, features, and advertising. | Usage Data | From our service providers | Consent |
To enable third parties to advertise products or services in which you may be interested, including via emails |
Identity Data
Usage Data Technical Data |
Directly from you
From our service providers |
Consent |
To enforce this Privacy Policy, our Terms of Use, and any other terms that you have agreed to, including to protect the rights, property, or safety of our users, or any other person, or the copyright-protected content of the Website |
Identity Data
Usage Data Technical Data |
Directly from you
From our service providers |
For purposes of legitimate interests |
To maintain and retain records in connection with actual and potential legal claims and regulatory investigations; and for governance & compliance purposes |
Financial Data
Identity Data Usage Data Technical Data |
Directly from you
From our service providers |
Necessary for the compliance with a legal obligation to which we are subject |
We will only use your personal data 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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
When we collect financial details, we are deemed to be collecting data that is "sensitive" under certain state privacy laws. We do not use or disclose sensitive personal information for any purpose other than as permitted by law, such as to provide our Service to you, to detect security incidents, and protect against malicious or fraudulent actions, nor do we use or disclose such information to build a profile about you.
4. How we share the information we collect
This section describes how the information collected or generated through your use of the Website may be shared by us with third parties.
4.1 Marketing and advertising
We share information with advertising partners in order to send you promotional communications about our Website or to show you more tailored content, including relevant advertising for third-party products and services that may be of interest to you, and to understand how users interact with advertisements. We also share personally identifiable information with third-party advertisers to enable them to provide you with opportunities to learn of products or services in which you may be interested.
We may also share aggregate user information in a non-personally identifiable manner with advertisers and other third parties in order to present to users more targeted advertising, products and services.
4.2 Service providers
We may from time to time share your information with third-party service providers to perform functions and process user data and help provide our Website or Service, consistent with this Privacy Policy. For example, we work with analytics providers to help us understand the use of our Website. Where a third party processes user data on our behalf, it is subject to security and confidentiality obligations consistent with this Privacy Policy and applicable law; we only permit them to process your personal data for specified purposes and in accordance with our instructions. Where a third party processes user data on its own behalf, its processing is subject to its own Privacy Policy and applicable law.
To provide you with the best experience on our Website, we use third parties who automatically process your Usage Data on our behalf. Where possible, we will make sure this data is anonymized.
For your information, click here to view some examples of how third parties process your personal data.
4.3 Affiliate networks
If you access our Website through an offer that you received or purchased from a third party, we may also share information with that third party about your use of the Website, such as whether and to what extent you have used the offer, activated an account, or actively used our Service.
4.4 Promotions and surveys
When one or more of our business partners co-sponsor a service, promotion, contest/sweepstakes, or survey, we may share some or all of the information collected in connection with such service, promotion, contest/sweepstakes, or survey with the co-sponsor(s). If we intend to share such information, you will be notified prior to the collection of that information. If you do not want your information to be shared, you will be able to choose not to allow the transfer by not using or signing up for that particular service, promotion, contest/sweepstakes, or survey.
5. Cookies and other tracking technologies
A cookie is a small text file that is placed on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers to recognize your device the next time you visit their website. There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, which indicate that a page or email has been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop software or mobile devices.
There are also technologies such as mobile device identifiers and SDK integrations to help companies recognize your device when you return to an app or otherwise use a service.
Our policy regarding cookies can be found here.
6. Information collected by third parties
Some entities that have links on our Website, such as advertisers, may collect personally identifying information such as your IP address when their ads are shown on our Site, or when you access or utilize those links. We do not control the collection or use of such information, and the practices of those entities are not covered by this Privacy Policy. For instance, if you click on an advertisement on our Website, you may be taken away to an entirely different site. Links can be from advertisers, content providers and/or partners who may use our logo and/or style as a result of a co-branding agreement yet they may still not follow the same policies as this Privacy Policy with respect to collection of your personal information. In addition, our Website includes social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features and related widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing them.
Please read these third parties' privacy policies to find out how they collect and process your personal information.
7. Email Opt-out
Users who no longer wish to receive our email updates or other notifications may opt out of receiving these communications by following the instructions contained in the applicable email or by logging in and changing their account settings. Please know that such a decision will not stop advertising or content that is generated prior to the time when we can accomplish the removal of your information.
8. Credit Card Processing
Credit card transactions are handled by a third-party processor that receives credit card numbers and other personally identifying information only to verify credit card accounts and process transactions.
Credit card security is an important aspect of the online experience. We use encryption technology to keep your credit card information safe. To ensure that your information is even more secure, once we receive your credit card information, it is stored on a server that isn't accessible from the Internet.
BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORISE US TO USE AND SHARE WITH CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE OF THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO US, EVEN IF SUCH INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROCESSING OF YOUR PURCHASE(S) AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS UNDER SUCH BANK SECRECY LAWS WITH REGARD TO US AND ANY TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH US.
9. Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered or disclosed, used or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know it. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, the transmission of data via the internet is not completely secure and we cannot guarantee that unauthorized parties will not be able to defeat those measures: unauthorized entry or use, hardware or software failure, and other factors may compromise the security of our user information at any time.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Children and COPPA compliance
Our site is not directed to children under the age of 13 and we do not knowingly collect data relating to anyone under the age of 18. We have designed this privacy policy in order to comply with the Children's Online Privacy Protection Act ("COPPA"). We will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to third parties. If a parent believes that his or her child has submitted personal information to us, he or she can contact us via e-mail or postal mail as listed below. We will promptly delete the information upon learning that it relates to a child under the age of 13. Please note that it is possible some of this information may remain archived in web logs and back-up archives after we delete the information from our active database.
We believe that parents should supervise their children's online activities and consider using parental control tools available from online services and software manufacturers that help provide a kid-friendly online environment. These tools can also prevent children from otherwise disclosing online their name, address and other personal information without parental permission.
11. Business transitions
In the event we go through a business transition, such as a merger, acquisition by another company, or sale of a portion of our assets, users' personal information will, in most instances, be part of the assets transferred. In such instance, the new owners may use your personal data in the same way as set out in this Privacy Policy.
12. Your consumer rights
Certain state laws grant their residents the rights set forth in this Section. It is our policy to allow our users to exercise these rights regardless of their residency. Please see the “Exercising Your Rights” paragraph below for instructions regarding how to exercise these rights.
Subject to certain limitations, you have the following rights with respect to the personal information that we collect about you:
If we have disclosed your personal data to any third parties for a business purpose over the past 12 months, we will identify the categories of personal data shared with each category of third party recipient. If we have sold your personal data over the past 12 months, we will identify the categories of personal data sold to each category of third party recipient.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use personal data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. If you do not receive a confirmation of our receipt of your request within 10 days, we may not have received your request and you should re-submit it.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. Once we receive your request, we will attempt to verify your identity. We may ask you for additional information to help us verify your identity, including by asking you to confirm other personal information you have provided to us. We may deny your request for reasons permitted by law, including our inability to verify your identity. If we deny your request, we will tell you why we did so.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper authorization and/or verify your identity as the requestor.
We Will Not Discriminate Against You for Exercising Your Rights
We will not discriminate against you for exercising your rights under this Section. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services. However, we may offer different tiers of our Service as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of personal data that we receive from you.
13. California users rights
If you are a California resident, you have the right to opt out of the selling or sharing of your personal data to/with third parties (subject to certain exceptions). It is important to note that sharing personal information with service providers who provide goods and services or perform other business functions on our behalf is not subject to this Section. For purposes of this Section, a service provider is not a "third party." This Section does not apply either to cases where a consumer directs us to share personal information with a third party or otherwise intentionally interacts with a third party via our Website.
As described in our cookie policy, we have incorporated cookies from certain third parties into our Website. These cookies allow those third parties to receive information about your activity on our Website that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Website or on other websites you visit. Under California law, sharing your data through third party cookies for online advertising may be considered a “sale” of information. You can opt out of these sales by following the instructions in this section.
We may sell your personal data to the following categories of third parties:
Over the past 12 months, we may have sold or shared the following categories of your personal data to categories of third parties listed above:
You can opt-out using the following methods:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale or sharing of your personal data for at least 12 months.
We do not sell or share the personal data of visitors to our Website who are not subscribers to our Service. Accordingly, the foregoing opt-out mechanism does not apply to such visitors.
To our knowledge, we do not collect, share or sell the personal data of minors under 16 years of age.
Annual Records
This chart provides statistics about our responses to requests from California residents under Section 12 above over the past calendar year:
Requests to Know | Requests to Delete | Requests to Opt-Out | |
---|---|---|---|
Requests received: | 0 | 0 | 0 |
Requests complied with: | 0 | 0 | 0 |
Requests denied: | 0 | 0 | 0 |
Median response time (in days): | 0 | 0 | 0 |
In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints regarding our Service with the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 1625 North Market Blvd., Sacramento, CA 95834, by telephone at (916) 445-1254 or (800) 952-5210, or by email to [email protected].
In addition, under California law you are entitled to be advised how we handle “Do Not Track” browser signals. We do keep track of your browsing activities when we serve you content, which enables us to tailor what advertisements we present to you. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
14. Users located outside of the United States
We make an effort to protect the personal information of all users of our Website. If you are unsure whether this privacy policy is in conflict with the rules applicable where you are located, you should not submit your personal information. IN ADDITION, IF YOU ARE LOCATED WITHIN THE EUROPEAN UNION, YOU SHOULD NOTE THAT YOUR INFORMATION WILL BE TRANSFERRED TO THE UNITED STATES, THE LAWS OF WHICH MAY BE DEEMED BY THE EUROPEAN UNION TO HAVE INADEQUATE DATA PROTECTION. Users of our Website located in countries outside of the United States who submit personal information do thereby consent to the transfer of that information to and/or storage of the information in the United States.
15. EEA/UK users’ rights under the GDPR; Swiss users’ rights under the revFADP
If you are located in the European Economic Area or the UK, or Switzerland, or if the EEA's or UK's General Data Protection Regulation ("GDPR"), or the Swiss revised Federal Data Protection Act (revFDPA) otherwise applies to your data as processed by us, you have the right to:
If you wish to exercise any of the rights set out above or request details about the specific legal basis we are relying on to process your personal data, please email us at [email protected] using the Subject Access Request Form.
We will respond to you within 30 days of receipt of your request. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise your other legal rights). This is a security measure to ensure that your personal data is not disclosed to any person who does not have the right to receive it. We may also contact you to ask you for further information, in relation to your request, to speed up our response.
You will not have to pay a fee to access your personal data (or to exercise any of your other legal rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to make a complaint at any time to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
You may make a complaint under the revFDPA here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt/kontaktformular_dritte.html
We would, however, appreciate the chance to deal with your concerns before you approach the authorities, so please email us at [email protected] in the first instance.
16. Data retention
We only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or internal reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for compliance, governance, legal and/or regulatory purposes in which case we may use this information indefinitely without further notice to you.
17. Cooperation with law enforcement; fraud protection
We fully cooperate with law enforcement agencies in identifying those who use our Website or Service for illegal activities. We reserve the right to disclose information about members who we believe are in violation of applicable laws or regulations, or as required to respond to a subpoena, court orders or other legal process requiring such disclosure. We also reserve the right to report to law enforcement agencies any activities that we reasonably believe to be unlawful and to exchange information with other companies and organizations for fraud protection.
18. Changes to this Privacy Policy
Occasionally we may, in our discretion, make changes to this Privacy Policy. When we make material changes to this Privacy Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g. by displaying a prominent notice within the Website or by sending you an email. In some cases, we will notify you in advance, and your continued use of the Website after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you object to any of the changes, you have the opportunity to delete your account and any associated information. Once deleted your details will be non-recoverable.
Please note that if you opt out of receiving notices from us, change notices will still govern your use of the Website, and you are responsible for reviewing such legal notices for changes, as posted on the Website.