GDPR PRIVACY NOTICE TEMPLATE
Last updated [month
day, year]
INTRODUCTION
Thank you for choosing to be part of our
community at [business name] (“company”, “we”, “us”, or “our”). We are
committed to protecting your personal information and your right to privacy. If
you have any questions or concerns about our policy, or our practices with
regards to your personal information, please contact us at [contact email].
When you visit our website [website] (“Site”)
and use our services, you trust us with your personal information. We take your
privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain
to you in the clearest way possible what information we collect, how we use it
and what rights you have in relation to it. We hope you take some time to read
through it carefully, as it is important. If there are any terms in this
privacy policy that you do not agree with, please discontinue use of our site
and our services.
This
privacy policy applies to all information collected through our websites (such
as [INSERT URL]), [our mobile] [or] [our Facebook applications] ("Apps"),
and/or any related services, sales, marketing or events (we refer to them collectively
in this privacy policy as the "Sites").
Please
read this privacy policy carefully as it will help you make informed decisions
about sharing your personal information with us.
Table of contents
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH
ANYONE?
4. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
5. DO WE USE GOOGLE MAPS?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED
INTERNATIONALLY?
8. WHAT IS OUR STANCE ON THIRD-PARTY
WEBSITES?
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. DO CALIFORNIA RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS POLICY?
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
WHAT INFORMATION DO WE COLLECT?
Personal
information you disclose to us
In Short: We collect
personal information that you provide to us such as name, address, contact
information, passwords and security data, payment information, and social media
login data.
We collect personal information that you
voluntarily provide to us when [registering at the Sites or Apps,] expressing
an interest in obtaining information about us or our products and services,
when participating in activities on the Sites [(such as posting messages in our
online forums or entering competitions, contests or giveaways)] or otherwise
contacting us.
The personal information that we collect depends on the context
of your interactions with us and the Sites, the choices you make and the
products and features you use. The personal information we collect can include the following:
Name and Contact Data. We
collect your first and last name, email address, postal address, phone number,
and other similar contact data.
Credentials. We collect passwords,
password hints, and similar security information used for authentication and
account access.
Payment Data. We collect data necessary
to process your payment if you make purchases, such as your payment instrument
number (such as a credit card number), and the security code associated with
your payment instrument. All payment data is stored by our payment processor
and you should review its privacy policies and contact the payment processor
directly to respond to your questions.
Social Media Login Data. We
provide you with the option to register using 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 "Social Logins" [LINK]
below.
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 IP address and/or browser and device
characteristics – is collected automatically when you visit our websites.
We automatically collect
certain information when you visit, use or navigate the Sites. 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 Site and other technical information. This information is primarily
needed to maintain the security and operation of our Sites, 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 Cookies Policy [Hyperlink]].
Information collected through
our Apps
In Short: We may collect information regarding your geo-location, mobile
device, push notifications, and Facebook permissions when you use our apps.
If you use our Apps, we may
also collect the following information:
·
Geo-Location Information. We may request access or
permission to and track location-based information from your mobile device,
either continuously or while you are using our mobile application, to provide
location-based services. If you wish to change our access or permissions, you
may do so in your device’s settings.
· Mobile Device Access. We may request access or permission to certain features from
your mobile device, including your mobile device’s [Bluetooth, calendar,
camera, contacts, microphone, reminders, sensors, SMS messages, social media
accounts, storage,] and other features. If you
wish to change our access or permissions, you may do so in your device’s
settings.
·
Mobile Device Data. We may automatically
collect device information (such as your mobile device ID, model and
manufacturer), operating system, version information and IP address.
·
Push Notifications. We may request to send you push notifications regarding your
account or the mobile application. If you wish to opt-out from receiving these
types of communications, you may turn them off in your device’s settings.]
·
[Facebook Permissions. 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, checkins, 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.]
Information collected from
other Sources
In Short: We may collect limited data from public databases, marketing
partners, social media platforms, and other outside sources.
We may obtain information
about you from other sources, such as public databases, joint marketing
partners, social media platforms (such as Facebook), as well as from other
third parties. Examples of the information we receive from other sources
include: social media profile information (your name, gender, birthday, email,
current city, state and country, user identification numbers for your contacts,
profile picture URL and any other information that you choose to make public);
marketing leads and search results and links, including paid listings (such as
sponsored links).
HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate
business interests, the fulfillment of our contract with you, compliance with
our legal obligations, and/or your consent.
We use personal information collected via our Sites for a
variety of business purposes described below. We process your personal
information for these purposes in reliance on our legitimate business interests
("Business Purposes"), in order to enter into or perform a contract
with you ("Contractual"), with your consent ("Consent"),
and/or for compliance with our legal obligations ("Legal Reasons").
We indicate the specific processing grounds we rely on next to each purpose
listed below.
We use the information we collect or receive:
·
To facilitate account
creation and logon process [with your Consent]. If
you choose to link your account with us to a third party account *(such as your
Google or Facebook account), we use the information you allowed us to collect
from those third parties to facilitate account creation and logon process. See
the section below headed "Social Logins" for further information.
·
To send you marketing and
promotional communications [for Business Purposes
and/or with your Consent]. We and/or our third party marketing partners may use
the personal information you send to us for our marketing purposes, if this is
in accordance with your marketing preferences. You can opt-out of our
marketing emails at any time (see the "Your Privacy Rights" below).
·
To send administrative information
to you [for Business Purposes, Legal Reasons and/or
possibly Contractual]. We may use your personal information to send you
product, service and new feature information and/or information about changes
to our terms, conditions, and policies.
·
Fulfill and manage your
orders [for Contractual reasons]. We may use your
information to fulfill and manage your orders, payments, returns, and exchanges
made through the Sites.
·
To post testimonials [with your Consent]. We post testimonials on our Sites that may
contain personal information. Prior to posting a testimonial, we will obtain
your consent to use your name and testimonial. If you wish to update, or delete
your testimonial, please contact us at [INSERT
CONTACT] and be sure to include your name, testimonial location, and
contact information.
·
Deliver targeted advertising
to you [for our Business Purposes and/or with your
Consent]. We may use your information to develop and display content and
advertising (and work with third parties who do so) tailored to your interests
and/or location and to measure its effectiveness. [For more information, see
our Cookie Policy [HYPERLINK]].
·
Administer prize draws and
competitions [for our Business Purposes and/or with
your Consent]. We may use your information to administer prize draws and
competitions when you elect to participate in competitions.
·
Request Feedback [for our Business Purposes and/or with your Consent]. We may use
your information to request feedback and to contact you about your use of our
Sites.
·
To protect our Sites [for Business Purposes and/or Legal Reasons]. We may use your
information as part of our efforts to keep our Sites safe and secure (for
example, for fraud monitoring and prevention).
·
To enable user-to-user
communications [with your consent]. We may use your
information in order to enable user-to-user communications with each user's
consent.
·
To enforce our terms,
conditions and policies [for Business Purposes,
Legal Reasons and/or possibly Contractual].
·
To respond to legal requests
and prevent harm [for Legal Reasons]. If we
receive a subpoena or other legal request, we may need to inspect the data we
hold to determine how to respond.
·
For other Business Purposes. We may use your information for other Business Purposes, such
as data analysis, identifying usage trends, determining the effectiveness of
our promotional campaigns and to evaluate and improve our Sites, products,
services, marketing and your experience.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share
information with your consent, to comply with laws, to protect your rights, or
to fulfill business obligations.
We only share and disclose your information in the following
situations:
· Compliance with Laws.
We may disclose your information where we are legally required to do so in
order to comply with applicable law, governmental requests, a judicial
proceeding, court order, or legal process, such as in response to a court order
or a subpoena (including in response to public authorities to meet national
security or law enforcement requirements).
·
Vital Interests and Legal Rights. We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential
violations of our policies, suspected fraud, situations involving potential
threats to the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
·
Vendors, Consultants and
Other Third-Party Service Providers. We
may share your data with third party vendors, service providers, contractors or
agents who perform services for us or on our behalf and require access to such
information to do that work. Examples include: payment processing, data
analysis, email delivery, hosting services, customer service and marketing
efforts. We may allow selected third parties to use tracking technology on the
Sites, which will enable them to collect data about how you interact with the
Sites over time. This information may be used to, among other things,
analyze and track data, determine the popularity of certain content and better
understand online activity. Unless described in this Policy, we do not share,
sell, rent or trade any of your information with third parties for their
promotional purposes.
·
Business Transfers. We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
· Third-Party Advertisers.
We may use third-party advertising companies to serve ads when you visit the
Sites. These companies may use information about your visits to our Website(s)
and other websites that are contained in web cookies and other tracking technologies
in order to provide advertisements about goods and services of interest to you.
[See our Cookie Policy [Hyperlink] for further information]
· Affiliates. We may
share your information with our affiliates, in which case we will require those
affiliates to honor this privacy policy. Affiliates include our parent company
and any subsidiaries, joint venture partners or other companies that we control
or that are under common control with us.
· Business Partners. We
may share your information with our business partners to offer you certain
products, services or promotions.
· With your Consent. We
may disclose your personal information for any other purpose with your consent.
· Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Sites) or otherwise interact with public areas of the Site [or App], such personal information may be viewed by all users and may be publicly distributed outside the Site [and our App] in perpetuity. [If you interact with other users of our Sites and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity.] Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.
· Offer Wall. Our Apps
may display a third-party hosted “offer wall.” Such an offer wall allows
third-party advertisers to offer virtual currency, gifts, or other items to
users in return for acceptance and completion of an advertisement offer.
Such an offer wall may appear in our mobile application and be displayed
to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will
leave our mobile application. A unique identifier, such as your user ID,
will be shared with the offer wall provider in order to prevent fraud and
properly credit your account.]
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect
and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy
DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better
service.
This website, mobile
application, or Facebook application uses Google Maps APIs. You may find the
Google Maps APIs Terms of Service here. To
better understand Google’s Privacy Policy, please refer to this link.
By using our Maps API
Implementation, you agree to be bound by Google’s Terms of Service. [By using our implementation of the Google Maps APIs, you
agree to allow us to gain access to information about you including personally
identifiable information (such as usernames) and non-personally identifiable
information (such as location). [We will be collecting the following
information: ] (information
list)
For a full list of what we use
information for, please see the previous sections titled “Use of Your
Information” and “Disclosure of Your Information.” [You agree to allow us to
obtain or cache your location. You may revoke your consent at anytime.] [We use
information about location in conjunction with data from other data providers.]
[The Maps APIs that we use
store and access cookies and other information on your devices. If you are a
user currently in the European Union, please take a look at our EU User Consent
Policy, which can be found at this link: [link from question].]
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our websites using a
social media account, we may have access to certain information about you.
Our Sites offers you the
ability to register and login 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, e-mail address,
friends list, profile picture as well as other information you choose to make
public. [If you login using Facebook, 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.]
We will use the information we receive only for the purposes
that are described in this privacy policy or that are otherwise made clear to
you on the Sites. Please note that we do not control, and are not responsible
for, other uses of your personal information by your third party social media
provider. We recommend that you review their privacy policy to understand how
they collect, use and share your personal information, and how you can set your
privacy preferences on their sites and apps.
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in
countries other than your own.
Our servers are located in [INSERT DETAILS]. If you are
accessing our Sites from outside [INSERT LOCATION OF SERVERS], 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 "Disclosure of Your Information" above), in
If you are a resident in the European Economic Area, then these
countries may not have data protection or other laws as comprehensive as those
in your country. We will however take all necessary measures to protect your
personal information in accordance with this privacy policy and applicable law.
Option 1: European
Commission's Standard Contractual Clauses Such measures implementing the European Commission's Standard Contractual
Clauses for transfers of personal information between our group companies and
between us and our third-party providers, which require all such recipients to
protect personal information that they process from the EEA in accordance with
European data protection laws. .
We have implemented similar appropriate safeguards with our third party service
providers and partners and further details can be provided upon request.
OR
Option 2: EU-U.S.
Privacy Shield Framework :
In particular [COMPANY] complies with the EU-U.S. Privacy Shield
Framework as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of personal information transferred from the
European Union to the United States and has certified its compliance with it.
As such, [COMPANY] is committed to subjecting all personal information received
from European Union (EU) member countries, in reliance on the Privacy Shield
Framework, to the Framework’s applicable Principles. To learn more about the Privacy
Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield
List.
[COMPANY] is responsible for the processing of personal
information it receives, under the Privacy Shield Framework, and subsequently
transfers to a third party acting as an agent on its behalf.
With respect to personal information received or transferred
pursuant to the Privacy Shield Framework, [COMPANY] is subject to the
regulatory enforcement powers of the U.S. 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.
OR
Option 3: Binding Corporate Rules (use this if you choose
to implement Binding Corporate Rules):
These include, a set of Binding Corporate Rules
("BCRs") established and implemented by [COMPANY]. Our BCRs have been
recognized by EEA 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 [INSERT LINK].]
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not
responsible for the safety of any information that you share with third-party
providers who advertise, but are not affiliated with, our websites.
The Sites may contain advertisements from third parties that are
not affiliated with us and which may link to other websites, online services or
mobile applications. We cannot guarantee the safety and privacy of data you
provide to any third parties. Any data collected by third parties is not
covered by this privacy policy. We are not responsible for the content or
privacy and security practices and policies of any third parties, including
other websites, services or applications that may be linked to or from the
Sites. You should review the policies of such third parties and contact them
directly to respond to your questions.
HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill
the purposes outlined in this privacy policy unless otherwise required by law.
We will only keep your
personal information for as long as it is necessary for the purposes set out in
this privacy policy, unless a longer retention period is required or permitted
by law (such as tax, accounting or other legal requirements). No purpose in
this policy will require us keeping your personal information for longer than
[90 days/6 months/1 year/2 years/the period of time in which you have an
account with us/90 days past the termination of your account/6 months past the
termination of your account/1 year past the termination of your account/2 years
past the termination of your account].
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize it, 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.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of
organizational and technical security measures.
We have implemented
appropriate technical and organizational security measures designed to protect
the security of any personal information we process. However, please also
remember that we cannot guarantee that the internet itself is 100% secure.
Although we will do our best to protect your personal information, transmission
of personal information to and from our Sites is at your own risk. You should
only access the services within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
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 Sites, 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 Site [and App]. 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 have
collected from children under age 18, please contact us at [INSERT CONTACT
EMAIL].
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: [In some regions, such as the European Economic Area, you have
rights that allow you greater access to and control over your personal
information.] You may review, change, or terminate your account at any time.
[In some regions (like the
European Economic Area), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and
obtain a copy of your personal information, (ii) to request rectification or
erasure; (iii) to restrict the processing of your personal information; and
(iv) if applicable, to data portability. In certain circumstances, you may also
have the right to object to the processing of your personal information. To
make such a request, please use the contact details provided below [HYPERLINK].
We will consider and act upon any request in accordance with applicable data
protection laws.
If we are relying on your
consent to process your personal information, you have the right to withdraw
your consent at any time. Please note however that this will not affect the
lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you
believe we are unlawfully processing your personal information, you also have
the right to complain 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 at any time review or
change the information in your account or terminate your account by:
·
Logging into your account
settings and updating your account
·
Contacting us using the
contact information provided below
·
[Other]
Upon your request to
terminate your account, we will deactivate or delete your account and
information from our active databases. However, some information may be
retained in our files to prevent fraud, troubleshoot problems, assist with any
investigations, enforce our Terms of Use and/or comply with legal
requirements.]
Cookies and similar technologies: Most
Web browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and to reject cookies. If
you choose to remove cookies or reject cookies, this could affect certain
features or services of our Sites. To opt-out of interest-based advertising by
advertisers on our Site visit http://www.aboutads.info/choices/. [For further
information, please see our Cookie Policy
Opting out of email marketing: You can unsubscribe from our marketing email list at any time
by clicking on the unsubscribe link in the emails that we send or by contacting
us using the details provided below. You will then be removed from the
marketing email list – however, we will still need to send you service-related
emails that are necessary for the administration and use of your account. You
can also opt-out by:
·
Noting your preferences at
the time you register your account with the Sites.
·
Logging into your account
settings and updating your preferences.
·
Contacting us using the
contact information provided below
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted
specific rights regarding access to your personal information.
California Civil Code Section
1798.83, also known as the “Shine The Light” law, permits our users who are
California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed
to third parties for direct marketing purposes and the names and addresses of
all third parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would like to
make such a request, please submit your request in writing to us using the
contact information provided below.
If you are under 18 years of
age, reside in California, and have a registered account with the [Sites/
Mobile Application/ Facebook Application], you have the right to request
removal of unwanted data that you publicly post on the [Sites/ Mobile
Application/ Facebook Application]. To request removal of such data, please
contact us using the contact information provided below, and include the email
address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the
[Sites/ Mobile Application/ Facebook Application], but please be aware that the
data may not be completely or comprehensively removed from our systems.
DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant
with relevant laws.
We may update this privacy
policy from time to time. The updated version will be indicated by an updated
“Revised” date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy policy, we may notify
you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy policy
frequently to be informed of how we are protecting your information.
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, email us
[Our Privacy Officer] at [INSERT CONTACT EMAIL] or by post to:
[If you are a resident in the
European Economic Area, the "data controller" of your personal
information is [INSERT NAME OF THE COMPANY]. [COMPANY, has appointed [INSERT
NAME] to be its representative in the EEA. You can contact them directly
regarding the processing of your information by COMPANY, by email at [INSERT
CONTACT EMAIL] or by post to: [INSERT ADDRESS].]
If you have any further
questions or comments about us or our policies, email us at [CONTACT EMAIL]
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