[Last Revised: May 21, 2018]
We have included below information about which data is collected, how we process and use your data, but before we would like to explain the basis on which we do so:
1. Where you sign up for any of our services, we process your personal data in order to perform our contract with you;
2. If we have a legitimate interest in processing data, such as for direct marketing or online identifiers; or
3. We will also process your personal data where you have provided us with consent to do so.
2. What information we collect?
The first type of information we collect is aggregated, non-identifiable, non-personal information, which may be made available or gathered via the user's use of the Service (" Non-Personal Information"). We are not aware of the identity of the user from which the Non-Personal Information was collected. The Non-Personal Information which is being collected may include technical information automatically transmitted by the user's device (for example, type of browser, the type of the user's device and technical information pertaining to the user's device, language preferences, time stamps, clicks and visited pages, search logs, the operating system, utilized internet service provider and other similar information.
The second type of information is individually identifiable information, namely information that identifies an individual or entity or may with reasonable effort identify an individual (" Personal Information"). The Personal Information we collect on or through the Service includes:
For avoidance of doubt, in the event Non-Personal Information is combined with Personal Information we will treat it as Personal Information as long as it is combined.
3. How we may collect your information?
Non-Personal Information may be automatically transmitted by the user's device. When using our Service, we assign your device with a log file, a cookie (session or persistent), web beacons or other related technologies, to collect Non-Personal Information with respect to your activity in connection with our Service.
A "cookie" is a small piece of information that a website assign to your device while you are viewing a web site. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help customize your experience. You can find more information about cookies at www.allaboutcookies.org . You may remove our cookie by following the instructions of your device preferences; however, if you choose to disable our cookie, some features of our Service may not operate properly and your online experience may be limited. You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser.
Google Analytics . This cookie is placed in order to track and analyze the use of our Services, for internal purposes. To learn more about how Google uses data from our use of Google Analytics Cookies, we recommend you review Google's policies located at: www.google.com/policies/privacy/partners . We also encourage you to review the Google Analytics' currently available opt-outs for the web tool available at: https://tools.google.com/dlpage/gaoptout/ .
4. How we use information we collect?
We collect Personal Information for the following purposes:
· The legitimate interest of operating the service.
· Recommend content based on your preferences.
· To respond to users' requests and feedbacks.
· To respond to claims that any content available through the Service violates rights of third-parties, to resolve disputes and enforce our policies, including investigation of potential violations thereof, for the purpose of law enforcement or in accordance with any applicable law or regulation.
We collect Non-Personal Information for the following purposes
· The legitimate interest of operating the service.
· To perform research, analytics or for statistical purposes.
· To detect, prevent, or otherwise address fraud, security or technical issues.
5. With whom we share information?
We do not sell, trade, or rent users' Personal Information to other parties. We may share information solely in the following events:
· we will share your information, solely to the extent needed to comply with any applicable law or regulation (including our policies and agreements), solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
· We may share Non-Personal Information with our trusted Service Providers only to the extent required to fulfill the purposes of providing the services.
· Other third parties (including retailers, media networks, feed providers) in any of the above circumstances, as well as for the purpose of developing or delivering content (whether via our Service, or websites, applications or services of third parties), or for the purpose of improving our Service, conducting business analysis or other business purposes. This information may be combined with information we collect from other sources, to the extent that the information remains Non-Personal Information.
· You may share through the Service certain types of information (e.g. music interests and recommendations) with other users.
6. Information Retention Policy and User Rights
Applicable data protection and privacy laws may provide you with the ability to exercise some user rights regarding your Personal Information collected by the Company (which might be different in each jurisdiction). The user rights are as follow: (i) you may request to access your Personal Information that we hold; (ii) you may request the rectification of your Personal Data that we hold; (iii) you may request the erasure of your Personal Information that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) you may request to restrict processing of your Personal Information; (v) you may object to processing of your Personal Information by us; (vi) you may request to exercise your right of data portability; (vii) you may exercise your right to file a complaint to a supervisory authority in your jurisdiction; and (viii) you have the right to withdraw consent.
To exercise any of the above user rights, please contact us at: firstname.lastname@example.org . In the event you make such request, note that we may require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take, however not more than one (1) month, unless otherwise required or permitted under applicable law.
Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply. Please note we may charge a small fee for such request, all in accordance with applicable laws.
Unless we are instructed otherwise by users, we retain the Non-Personal Information, we collect for as long as needed to provide the Service and to comply with our legal obligations, resolve disputes and enforce our agreements. Further, we retain the Personal Information, we collect for as long as legally permissible, in accordance with applicable laws.
7. Children Information
Your privacy is very important to the Company and therefore we are committed to protecting your Personal Information from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. The Personal Information collected by the Company is stored in the Google Big Query Cloud servers, for more information regarding the data security provided by Google, please see: https://cloud.google.com/security/ .
Company seeks to minimize the amount of data that it stores on its servers in the first place. If you feel that your privacy was treated not in accordance with our policy, or if any person attempted gain unauthorized access to the Personal Information please contact us at: email@example.com.
Further, in the event of a data incident, in which we discover your Personal Information may be at risk, then we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws).
9. Transfer of Data
10. Do Not Track Disclosure
Our Service does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.
11. Contacting us
Data protection officer
Our data protection officer's contact details are: firstname.lastname@example.org.