Last updated on 10. March 2020.
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].
WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
DO WE USE GOOGLE MAPS?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
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.
[DN: INCLUDE IF USING SOCIAL MEDIA INTEGRATIONS] 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.
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]].
[DN: FOR MOBILE OR FACEBOOK APPLICATION ONLY:
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.]
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).
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:
[DN: INCLUDE AS APPLICABLE TO THE SITE]
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.
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.
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:
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.
[FOR MOBILE APPLICATION ONLY:
In Short: Yes, we use Google Maps for the purpose of providing better service.
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].]
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.]
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 [INSERT DETAILS OF DESTINATION COUNTRIES] and other countries .
Option 1: European Commission's Standard Contractual Clauses (use this if you choose model clauses as a ground for international transfers): 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. [Our Standard Contractual Clauses can be provided upon request / are available here [link]]. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.
Option 2: EU-U.S. Privacy Shield Framework (use this if you choose the Privacy shield framework as a ground for international transfers:
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.
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].]
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.