DATA USAGE POLICY
Effective as of April,18 2019
This Data Usage Policy may be subject to change in the future. Every time we make changes, we will publish a new version of the Data Usage Policy at this page and will point the date of revision.
“Personal Data” - data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual.
“Non-Personal Data” – data in a form that does not, on its own, permit direct association with any specific individual.
“Information”– both Personal and Non-Personal Data.
“Regulation” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
“Law” – data protection and other laws and regulations of state of Illinois, USA applicable to the subject matter, and Regulation as determined above.
1. INFORMATION THAT WE MAY COLLECT
As you use the Products and/or the Services and/or interact with the Website, we may collect and process Information from and about you. We obtain such Information from various sources described below.
Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from the Products, the Services and/or the Website if that information is necessary to provide you with the service or if we are legally required to collect it.
If we do combine Non-Personal Data with Personal Data the combined data will be treated as Personal Data for as long as it remains combined.
A.Personal Data Provided by You
Contact and Account Information. When you access or otherwise use the Website or register / sign up for the Products, we may collect certain contact information from you, such as your username and email. This information is required by us to verify your identity, to establish your account, and set up the Products and the Services. After completing registration, you may have the possibility to provide optional account information (e.g. your photo, first and last name, ocupation, city, state and zip code, email address, education, relationship status, hobbies, interests, favorite music, favorite films, password, or other contact details to help you with your experience as established in registration form).
During registration, a user is required to provide the abovementioned Information as described in this Data Usage Policy and choose password. By refusal to provide Information that is necessary for registration and establishing your account, you refuse to receive the Products and the Services.
Other Information. You may provide us with Information when you interact with us in other ways, such as when you submit requests or questions to us via forms or email (e.g., support forms, sales forms, user research participation forms, surveys, blog subscription); information you provide in connection with our contests, or research studies in which you choose to participate; beta testing; and requests for customer support and technical assistance; your interests, photos, links, etc. (collectively, “Other Information”). Participation in our surveys or contests, filling our forms, etc. is voluntary and you may choose whether or not to participate and therefore disclose this information. Such information will be used for purposes of monitoring or improving the use and satisfaction of the Products and the Services.
B.Information Automatically Obtained From Your Interactions with the Service, the Website and the Products
Cookies and Similar Technologies. We use “cookie” technology to collect additional website usage data and to improve the Website, the Products and the Services.
Log Data. When you use the Products, the Services and/or the Website, our servers automatically record information that your browser sends whenever you visit Website (“Log Data”). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, language preferences, the web-pages you visit, the search terms you use, and any advertisements you may click on. We use this Information to understand and analyze trends, to administer the Website, to learn about user behavior on the Website, to improve the Products and Services, and to gather demographic information about our user base as a whole. We may also use this Information in marketing and advertising services as described below.
Links to Other Websites. The Products, the Services and/or the Website may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer/other device, collect data or solicit Information from you. Other Websites follow different rules regarding the use or disclosure of the Personal Data you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party Websites or services to which links or access are provided through the Website, Service, Products. We encourage you to read the privacy policies or statements of the other websites you visit.
Service Information.In order to provide Services to you and to improve your experience, we may collect Information that is created or provided by you in connection with your use of the Products, the Services and/or the Website (collectively, “Service Information”). Service Information may include Personal Data.
Device information – when you access the Website, Service, Products using an electronic device, we collect certain device information, including the type of device you are using, its operating system (OS), and network information, which may include your Google AID and/or Apple IDFA. We may also collect other unique device identifiers such as advertiser ID.Location information – we collect and process general information about the location of the device from which you are accessing the Service (e.g., approximate geographic location inferred from an IP address).Information you share and provide — photos, interests, texts, links and other data which may include Personal Data.
C. Information Collected through Social Media
The Products, the Services and/or the Website may contain links to other websites, including Social Media, such as Facebook, Twitter, LinkedIn and Medium. Such links provide you the ability to connect with us through Social Media channels.
Please, notice that when you click on such Social Media links and leave the Website, we do not have any control over such third party Social Media. We are not responsible for the content, privacy and security practices, and policies of third-party Websites or services (including Social Media) to which links or access are provided through the Website, Service, Products. We encourage you to read the privacy policies or statements of the other websites you visit.
Moreover, the Website and the Products may include Social Media features and widgets (the “Features”). These Features may collect your IP address, which page you are visiting on the Website, the Products and may set cookies to enable the Feature to function properly. Features are either hosted by a third party or hosted directly on the Website and/or the Products. Your interactions with these Features are governed by the Data Usage Policy of the company providing it.
C. Information You Share
When you use the Products, the Services and/or the Website, or post on forum, chat room, board, or Social Media service, the Personal Data and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Data you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. By submitting actions pointed above you grand us, our partners and affiliates a non-exclusive, unlimited, worldwide, royalty-free license to use, display, perform, copy, transmit, distribute, promote, alter, modify, manipulate or create derivative works with materials, texts, words, impressions and other information provided by you in such a way.
If you do not wish to have this information to be shared, do not initiate these connections and actions.
2. HOW WE MAY USE YOUR PERSONAL INFORMATION
We may use Information collected from as described above in the following ways:
Provision of the Services. We may use your Contact and Account Information to provide access to the Products and the Services to you, to create your account, respond to your inquiries and provide you with a support (including technical and customer support), technical updates or updates on changes in our usage policies. We also may use such Information to communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance (e.g. emailing you service-related announcements) and for direct marketing. You may refuse or revoke your consent to use your Personal Data for the above purposes at any time by terminating a subscription/deactivating your account and/or contacting us via the email address provided in this Data Usage Policy (excluding cases when we may collect and process such Information on the basis of our legitimate interest to the extent permitted by applicable law and Regulation).
Notifications. We may send you notices from time to time relating to your account, the Products and the Services provided to you. These may include Service confirmations and/or notifications, renewal notices, invoices etc. We may also send you service-related announcements when we decide it is necessary to do so; for instance, if the Website, the Products and/or the Services is temporarily suspended for maintenance, or the provision of the Service is delayed or canceled etc. These communications are necessary to the operation of the Products, the Services and/or the Websites and are not promotional in nature. You may opt-out of receiving these communications, though, it may lead to termination of your use/access of the Products and the Services due to impossibility of maintenance of contact with you.
Analytics, surveys, researches. Service Improvement.As it was mentioned above, from time to time, we may conduct surveys, question forms, test features etc. (“Improvement Activities”), and analyze the data we have to develop, evaluate and improve these features, all in order to improve the Website, the Service, the Products, Products and think of new and exciting features for our users.We may use any Information collected from you by such Improvement Activities (including Information obtained with Cookies and similar technologies, Log Data, Service Information, Other Information): (i) to personalize user's experience and to allow us to deliver the type of content and service offerings in which you are most interested in; (ii) to improve the Products in order to better serve you and/or to provide the Services more effectively; (iii) to ensure continuous improvement and development of the Products; (iv) to administer the Website, the Products and the Services and to diagnose possible problems; (v) for statistical and analytical purposes.
We may collect information regarding users’ activities on the Website and the Products and from our other products and services. This information is aggregated (so no end-user can be identified) and used to help us provide more useful information to our users and to understand which parts of the Website, the Services or the Products are of most interest.
We may collect information such as occupation, language, zip code, area code, device identifiers, location, and the time zone where the Products are used so that we can better understand user/customer behavior and improve the Website, the Products, the Services and advertising.
We may collect and store details of how you use the Products. This information may be used to improve the relevancy of provided by the Products results. Such information will not be associated with your IP address.
Promotional Offers and other Marketing Purposes.We may use Information obtained from you (e.g. your Contact Information) for the Marketing Purposes. For example, by subscribing to our newsletter you may receive tips and announcements straight to your email account. We may also send you promotional material concerning the Products, the Services and/or the Website or our partners’ services (which we believe may interest you).
In some of our email messages, pop-ups, banners and other advertising materials we may use a “click-through URL” link ed to content on the Website or the Products. When users/customers click one of these URLs, they pass through a separate web server before arriving at the destination page on the Website or the Products. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this Information to reduce or eliminate messages sent to users/customers.
You may choose not to receive our promotional or marketing emails (all or any part thereof) by clicking on the “unsubscribe” link in the emails that you receive from us. Moreover, in order to unsubscribe, you can contact us at any time via email address provided in this Data Usage Policy.
Please note that even if you unsubscribe from our promotional or marketing emails, we may continue to send you Service-related notifications, or reply to your queries and feedback you provide us. Moreover, we may still use and share your Information with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services.
Protection of our interests, Safety.We may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of the Products, the Services and/or the Websites and protect the rights and property of our Company, its users and/or partners. As a way of example, we may collect Personal Data to form conversion IP whitelist.
Compliance with Legal and Regulatory Requirements.We may also use/disclose your Information collected by us in order to comply with applicable legal requirements, industry standards and our policies. We may disclose your Information in situations that we believe to be: (1) emergencies involving potential threats to the physical safety of any person or property if we believe that your Information in any way relates to that threat; (2) you use the Products, the Services and/or the Website in a way that we believe may be illegal or inappropriate.
Note to Users Resident in the European Economic Area:If you are located in the European Economic Area or Switzerland, we may process your Personal Data for the abovementioned purposes when:
you have consented to the use of your Personal Data (e.g., we may seek to obtain your consent for our uses of cookies or similar technologies);we need your Personal Data to provide you with services and products requested by you under our contractual relations, or to respond to your inquiries;we have a legal obligation to use your Personal Data; orwe have a legitimate interest in using your Personal Data. In particular, we have a legitimate interest in using your Personal Data to ensure and improve the safety, security, to suppress illegal activity on the Website, the Products or with the use of the Products, the Services and/or the Websites, to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the rights and property of our Company, its users and/or partners etc.
3. HOW WE MAY SHARE AND TRANSFER THE INFORMATION
We pay particular attention to the protection of your Personal Data. We may disclose the Information we collect about you as described herein or otherwise share your information with the following entities, including those outside the European Union or the European Economic Area:
Internal Concerned Parties.We may share your Information with companies, who are our subcontractors, as well as with our employees, in order to provide you with the Products, the Services and/or the Websites. Our employees have limited access to your Information on a “need to know” basis and are bound with non-disclosure contractual obligations.
Service Providers.We may use third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services. When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data and not to use it for any purpose other than providing services to us and other provisions as required by law and Regulation.
Our third party service providers are based mainly in the European Economic Area (EEA) and USA. If you are located in the EEA or Switzerland, when transferring your Personal Data outside the EEA or Switzerland, we will comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA or Switzerland and make sure that our third party service providers can guarantee a high level of Personal Data protection. These guarantees may include, e.g. use of standard contractual clauses adopted by the Commission (EU) or participation in the “Privacy Shield” program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of protection provided by the EU-US Privacy Shield.
We use such third-party service providers:
Type of Personal Data
Google, LLC; Alphabet Inc. (parent company)
Analyzing Data for marketing purposes and improvement of the Products and Services
Google, LLC; Alphabet Inc. (parent company)
Analyzing Data for marketing purposes and improvement of the Products and Services
Analyzing Data for marketing purposes and improvement of the Products and Services
Spaces Object Storage
Data storage and database maintenance services
All categories of Information
We may also share your Information with other service providers for the abovementioned purposes, with which we will establish cooperation.
Compliance with laws and law enforcement entities.We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law and Regulation, we may disclose any Information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Company or a third party, to protect us against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service, the Products, the Website or the Products and any equipment used to make the Service available, or to comply with the law. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by applicable law, statute, court or administrative order.
Business Transfers. We reserve the right to sell, transfer or otherwise share some or all of our assets, including Personal Data, in connection with, including but not limited to, a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You acknowledge that such transfers may occur and that any acquirer or successor of ours may continue to use your Personal Data as set forth in this Data Usage Policy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Data Usage Policy.
Other Third Parties. We may also make certain Non-Personal Data available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, functionality available through the Service, statistics and other use. This is not linked to any Personal Data that can identify any individual person.
We will make commercially reasonable efforts to store Personal Data of individuals in the regions where they live or operate in cases if we are required by Law and/or Regulation to do so (e.g. Personal Data of EU citizens in EU or countries acknowledged by relevant authority as having appropriate level of data protection). However, please, note that some data recipients may be located outside the EEA and Switzerland, as it was mentioned above. By submitting your Personal Data, you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, center of vital interests, economic region, etc.). We will comply with applicable legal requirements for the transfer of Personal Data to countries outside of the EEA or Switzerland. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection. As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Moreover, before transferring any Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make reasonable check of such third party regarding its compliance with law and Regulation.
4.HOW WE PROTECT YOUR INFORMATION
We will maintain industry-standard physical, electronic and procedural safeguards designed to protect data in our possession from loss, misuse, any use not pointed in this Data Usage Policy and unauthorized access. Wherever we collect Personal Data, we make all commercially reasonable efforts to provide the necessary level of protection, as required by the Law and/or Regulation. We can provide such security measures by using third parties (e.g. processors, contractors etc.).
We use such measures to keep your Information safe:
Employees.We chose our employees after a strict background check regarding their business reputation, whether involved in scandals, etc. Each employee has to take probation during which we check his skills, but also his reliability, honesty, his fit for our corporate culture, law abidingness, etc.We limit access to your Information for our employees on a “need to know” basis. The employee gets access only to that Information that he directly needs to perform his work. Moreover, each employee is bound with contractual non-disclosure obligations (NDA), which will remain in force even after the termination of the relationship between the employee and the Company.
Data transmission between Company’s subdivisions and employees is not allowed, except when directly authorized by the top management personnel or expressly provided in their job description.
Staff training. To make sure Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the Company. We give our employees a briefing (training) regarding the following: on safety and rules for handling Data (including the requirements of the GDPR); when moving away from the workplace, the employee blocks his/her computer; it is forbidden to install any software on the workstations without the permission of the system administrator; it is forbidden to store Data (in any form) in unprotected locations (environment); it is forbidden to take Data carriers outside the office.
We constantly improve our Data protection mechanisms and methods of training employees.
Access control. We maintain industry-standard physical, electronic and procedural safeguards designed to protect Personal Data in our possession from loss, misuse, and unauthorized access. We provide following security measures: access to the building by an individual card through the security point; access to the offices through code and fingerprint; in different offices there are different code and fingerprints for access, which allows the employee to enter only to the office assigned to him (access to all offices is provided only to the top management personnel); access to the working computer by password and login (only the employee knows); access to the Products with Data only by the employees user ID and password.
Relations with contractors and third party service providers. In addition to abovementioned security measures that we provide when cooperate with third party service providers, we also choose our contractors (subcontractors) on the same principles, on which we select employees. Contractors come for a specific task. They delete all received Data after the job is completed. They also sign the NDA on the same principles as our employees. They receive access only to the Data that is directly necessary for the task.
We choose only those contractors and third party service providers that have long been on the market and have established themselves as exceptional companies with a perfect reputation. An exception may be the need to use a contractor from a completely new sphere in which there is still no established market and companies a long time working on it; in such cases, we will implement all the necessary additional measures of data control and protection, as required by law.
The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of storage, is 100% secure. While we strive to use commercially acceptable means to protect your Information, we cannot guarantee that the Website or the Data stored during your use of the Products is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Website, the Products or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your Personal Data and Non-Personal Data will always be secure.
Moreover, notice that you are solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting Information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Service, and you do so at your own risk.
Your obligations regarding security of your Data are the following: not to disclose your contact information and other data, which allows/enables unauthorized access to the Products and/or Website or any other actions, connected to the Products and/or Website on your behalf; make reasonable efforts to secure your actions in Internet and your use of the Products. You are solely responsible for the correctness, appropriateness fullness etc. of the provided data and warrant to us that you have all rights to provide us with such data.
5. YOUR RIGHTS AND CHOICESREGARDING YOUR INFORMATION
Regarding your Information you are entitled to:
A. the right to express and withdraw consents, including reading or registering cookies,
B. the right to objection, including:
objection to the processing of your Data for direct marketing purposes;reasoned objection to the processing of your Personal Data within the legitimate interests of our Company, for reasons related to your particular situation;objection to the processing of your Data for any other purpose, pointed in this Policy. Notice, that such objection may lead to impossibility to use the Website, the Service, the Products and/or may lead to termination of our contractual relations with you (if any);
C. the right to access your Data, including obtaining a copy of the Data to be processed (at our choice: in written, or by providing access to your Personal Data on our server (other type of storage), or sending it to you by email or on CD/DVD/other device, or in other applicable way, etc.);
D. the right to rectify (correct) your Personal Data if your Data in our possession is inaccurate or incomplete;
E. the right to delete your Data if your Data is no longer necessary for the purpose for which it was collected, and Company has no grounds for its processing, e.g. based on your consent or legal obligation. Moreover, you may ask to delete your Data at any time, but in such case it may lead to impossibility to use the Website, the Service, the Products and/or may lead to termination of our contractual relations with you (if any);
F. the right to transfer your Data provided to us by you in a machine-readable format, e.g. if you want to share it with another service provider;
G. the right to restrict processing of your Personal Data by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
In addition to the abovementioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.
You also have the right to express your concern regarding our data policies. In order to exercise this right you should send relevant request via email pointed in this Data Usage Policy.
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us via email pointed in this Data Usage Policy.
In order to fulfill your request, we are required to verify your identity so that your data does not go to an unauthorized person. In case if you send a relevant request on behalf of company (in cases where Personal Data may be applicable to the company as pointed in Law and/or Regulation), we should be sure you are duly authorized to receive such data about such company. As a way of example, but not limited to: if you send request from the same email you used during registration and with the same signature you usually use in your emails (if there were any between us), we reasonably consider that it is you, who asks for your Personal Data. In cases if you use other email address, or company asks data about itself through other employee (not the one who registered it in the Products) we shall ask for additional verification (unless such additional emails/persons were pointed as trustworthy during registration).
Company, within one month of receiving your request, shall provide you with information about the actions taken in connection with your request. If necessary, the deadline for your request can be extended up to 60 days due to the complex nature of the request or the number of requests.
In cases, if you found out that someone illegally provided us with your Personal Data, let us immediately know about this via our contact email pointed in this Data Usage Policy. Upon your request, we will delete your Personal Data without undue delay, but in any case within one month from the day of receipt of your request (or 60 days due to the complex nature of the request or the number of requests). We will only retain such copies of the information as are necessary for us to comply with law and Regulation for such cases.
If your request turns out to be unreasonable or excessive, in particular due to its repeated nature, we may request a reasonable fee for the fulfillment of the request or refuse to take action in connection with the request.
In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you and the relevant Data Protection Authority know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in the following ways we consider most appropriate: via your contact email, by phone, in your personal account, in national news, on the Website or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if you are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.
6. RETENTION PERIOD
We will retain your Personal Data for as long as necessary to provide the Products, the Services and/or the Websites, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Information at the earliest reasonable time. We make commercially reasonable efforts to store your Personal Data no longer than for 3 months. After such period, we make a revision of it. However, as it was mentioned above, we may delete your Personal Data at any time before such 3-month period terminates, in case if purpose we collected it for is no longer applies. We make no warranties your Personal Data will be available for any specific period of time (3 months, or less or more etc.). Please consider that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.
Please, notice that under applicable regulations, we may keep records containing client/customer/user Personal Data, billing information, communications and anything else as required by applicable laws and regulations or on a basis of legitimate interest (e.g. for defending our interests).
We understand the importance of taking extra precautions to protect the privacy and safety of children accessing the Website and/or the Products. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction (e.g. European Union residents may have other minimum age for providing of personal data), are not permitted to use the Website and/or the Products, unless their parent provided verifiable consent or as part of the child account creation process (if this type of account is applicable). We do not knowingly collect Personal Information from children under 13, or equivalent minimum age depending on jurisdiction. If we learn that we have collected the Personal Data of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, unless we are obliged to keep such data in order to comply with Law and/or Regulation.
If at any time a parent needs to access, correct, or delete such Personal Data he may contact us through email pointed in this Data Usage Policy.
8. OTHE PROVISIONS AS REQUIRED BY LAW
A. Do Not Track Signals
We use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords to track you over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals. As well, be aware that some third party Websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
B. Notice for Minors
We offer the interactive Products, which allows you to post content to share publicly or with friends. At any time, you can delete or remove content you have posted using the deletion or removal options within the Products. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact us via email pointed in this Data Usage Policy. Although we offer deletion capability for the Products, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the Products.
You should acknowledge that deleting/stop of use of the Products does not automatically mean that we have no of your Personal Data or that we as well deleted all of your Personal Data we have. In order to have your Personal Data deleted you should contact us via email pointed in this Data Usage Policy.
9. UPDATES TO THIS Data Usage Policy
Whenever we make an update of this Data Usage Policy it will be available on the Website with the mark “new version updated ...”.
You acknowledge and voluntarily agree that we have no obligation of sending you via email or otherwise any notification regarding such change, though we have right to do so if consider it appropriate (e.g. in the event that the modifications materially alter your rights or obligations hereunder).
You can access the new version of Data Usage Policy from the same day as it comes to affect – so you have the time to make a decision regarding the further use of the Website and the Products . As well, we can make a draft of new Data Usage Policy available in advance if we will consider it appropriate.
If you won’t agree to the new purposes of processing, you should contact us via email pointed in this Data Usage Policy with the relevant statement and immediately stop using the Products and the Services. You are advised to check for updates regularly. Your continued use of the Service and the Products after the revised Data Usage Policy has become effective indicates that you have read, understood and agreed to the current version of this Data Usage Policy.
10. NO RIGHTS OF THIRD PARTIES
This Data Usage Policy does not create rights enforceable by third parties or require disclosure of any Personal Data relating to users of the Website.
11. QUESTIONS AND COMPLAINTS
If you have any questions, concerns or complaints regarding the way we collect and handle your Personal Data, or if you have any thoughts or questions about this Data Usage Policy, or regarding contact person (representative) for compliance with law and Regulation please contact us firstname.lastname@example.org.