Template for Privacy Policy

1.  Definitions

When we say “we,” “us”, “our,” and “___________” we are referring to __________________________________ (Company name and physical address)

We provide __________________________________ (business description) (the “Services”).

When we say “you,” or “User,” we are referring either to a person who used our Services, subscribed to our emails or to some other person who visits any of our Websites.

“Personal Data,” “Personal Information” means any information that identifies or can be used to identify you directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information.

You must read this Privacy Policy attentively before using our Services.

2. General

We offer the Services on our website ________________ (address).

This Privacy Policy applies to this website, as well as any other sites or mobile applications owned or operated by us (each a “Website” and together the “Websites”). The “Websites” include the Websites themselves, and any web pages, interactive features, applications, widgets, blogs, social networks, social network “tabs,” or other online, mobile, or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device, or other technology, manner or means.

While providing the Services, and as described in more detail below, we may collect Personal Data about you.

This Privacy Policy covers our treatment of Personal Data that we gather when you are accessing or using our Services, but not to the practices of companies we don’t own or control, or people that we don’t manage.

We do not knowingly collect or solicit Personal Data from anyone under the legal age (according to your jurisdiction). If you are under the legal age (according to your jurisdiction), please do not attempt to register for the Services or send any Personal Data about yourself to us.

If we learn that we have collected Personal Data from anyone under the legal age (according to your jurisdiction), we will delete that data as quickly as possible. If you believe that anyone under the legal age (according to your jurisdiction) have provided us Personal Data, please contact us at____________

2.1. Your consent

By using or accessing the Service in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and your’re explicitly opt-in to the storage, use and management of your Personal Data by us and our Service Providers for the purposes specified below.

Consistent with the uses of Personal Data covered in this policy, we may transfer Personal Data to companies that help us promote, provide, or support our Services. All Service Providers enter into a contract with us that protects Personal Data and restricts their use of any Personal Data consistent with this policy. As part of our Services, we may use and incorporate into features your Personal Data. We may share this information with third parties in line with the approved uses in this policy.

2.2. Use and disclosure of personal information

We may use and disclose Personal Data only for the following purposes:

• For registration with our Service.
• To perform a contract in which you are involved as a party.
• To promote use of our Services to you and others.
• To send you informational and promotional content in accordance with your marketing preferences.
• To bill and collect money owed to us.
• For your participation in contests and loyalty programs.
• To send you System Alert messages.
• To communicate with you about your account and provide customer support.
• To enforce compliance with our Terms of Use and applicable law.
• To protect the rights and safety of our Users and third parties, as well as our own.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide, support, and improve the Services we offer.
• To provide suggestions to you.
• To transfer your information.

3. Contact us

If you have any questions or comments, or if you want to update, delete, or change any Personal Data we hold, or you have a concern about the way in which we have handled any privacy matter, please contact us at____________.

You may also contact us by postal mail at:

____________________________________

4. Changes

We are constantly trying to improve the Service, so it may change over time and we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice on our website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us, those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in effect on each respective date you visited the Website.

5. Your data

5.1. Data provided by you

Data you voluntarily provide to us: when you sign up for and use the Services, consult with our customer support team, send us an email, integrate the Services with another website or service, or communicate with us in any way, you are voluntarily giving us information that we collect. That data may include your

• name
• email address
• physical address
• IP address
• phone number
• age

as well as details including gender, occupation, location, purchase history, and other demographic information.

By giving us this data, you consent to this data being collected, used, disclosed, transferred and stored by us, as described in our Terms of Use and in this Privacy Policy.

5.2. Data collected automatically

Whenever you interact with the Service, we automatically receive and record information about your visit to our Websites, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Websites or other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies.

We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Service – for example, this data can tell us how often users use a particular feature of the Service, and we can use that knowledge to make the Service interesting to as many users as possible.

5.3. Cookies and tracking

We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies on our Website, such as pixels and web beacons, to analyze trends, administer the website, track users’ movements around the website, serve targeted advertisements, and gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. We partner with third parties to display advertising on our website or to manage and serve our advertising on other sites. Our third party partners may use cookies or similar tracking technologies in order to provide you advertising or other content based upon your browsing activities and interests. This Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features.

5.4. Information from other sources

From time to time we may obtain information about you from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Data) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.

We may combine Personal Data with other information we collect or obtain about you (such as information we source from our third party partners), to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this Privacy Policy. When we combine Personal Data with other information in this way, we treat it as, and apply all of the safeguards in this Privacy Policy applicable to, Personal Data.

5.5. Anonymous information

We may create Anonymous Information records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Information to analyze request and usage patterns so that we may enhance the content of our Services and improve website navigation. We reserves the right to use Anonymous Information for any purpose and disclose Anonymous Information to third parties in its sole discretion.

6. Public information and third party websites

Our Websites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

Our Websites include social media features. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

7. Your specific rights regarding personal data

Right of access: This Privacy Policy describes what data we collect and how we use it. As mentioned above, you may contact us directly to request access to information that we hold and request other information according to Article 15 EU GDPR.

Right to erasure (Right to be forgotten): You may terminate your account at any time, in which case we will permanently delete your account and all data associated with it.

Right to rectification: You may access and update your account settings at any time to correct or complete your account information upon your request at any time. You may also contact us at any time to access, correct, amend or delete information that we hold about you.

We will give you access to any Personal Data we hold about you within 30 days of any request for that information. You may request to access, correct, amend or delete information we hold about you by contacting our support (___________). Unless it is prohibited by law, we will remove any Personal Data about you from our servers at your or their request. There is no charge for an individual to access or update their Personal Data.

Right of portability: We will export your account data to a third party at any time upon your request.

8. Email tracking

Our servers do not record email addresses of visitors unless expressly specified for purposes such as means of identification for a service or tool available for registered and/or restricted use.

We keeping your email addresses in order to send you messages or company news, email addresses may be used also to market our products.

However, if you wish to avoid receiving any future mailings from us, please:

• choose to unsubscribe from receiving our news and updates at _____________________) or
• reply back to our message with ‘UNSUBSCRIBE’ in the subject line.

9. Disclosing personal information to the third parties

We may disclose Personal Data to the following types of third parties for the purposes described in this policy:

1. Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like receiving our news and updates), then we may share your Personal Data with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Data only for the provision of services to us and in a manner that is consistent with this policy.
2. Advertising partners. We may partner with third party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Data with them for this purpose. All third parties with which we share this information are required to use your Personal Data in a manner that is consistent with this policy.
3. Social media as described above.

10. Contests

We may, from time to time, offer surveys, contests, loyalty programs or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.

11. Storing information under your account

Information placed and stored on our Websites, designed for the storage and retrieval of personal data or providing you the services you have requested is tied to the username and password of the member whose Internet account information is stored under.

We will use and disclose the information stored under your account only for the reasons discussed above.

12. Accuracy and retention of data

We will retain your Personal Data for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.

We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes, then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Data. We will retain your information for as long as your account is active or as long as needed to provide you with our Services.

13. Your personal data protection

We take reasonable and appropriate measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

We don’t store individual Internet account passwords in the accessible format, and will not divulge or change any passwords on any account without proper authorization from the account owner or responsible party.

In addition, any information collected through our websites or over the Internet is transmitted using current industry-standard security and/or encryption methods aimed at protecting our customer’s information from unauthorized access or use.

We recommend that you always keep your password private, and change it periodically in order to better protect your personal data.

If a security breach causes an unauthorized intrusion into our system that materially affects your Personal Data, then we will notify you as soon as possible and later report the action we took in response.

Our servers and offices are located in ___________________________ so your information may be transferred to, stored, or processed in that countries. While the data protection, privacy, and other laws of that countries might not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in that  countries and those third parties with whom we share it as described in this policy. If applicable

We guarantee that any actions regarding Personal Data are carried out in full compliance with this Policy and the principles set forth in the EU GDPR.

Updated ________

Last Updated: 27.07.2023