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Privacy Policy
California Notice at Collection: For California residents, see the California privacy rights section below for important information about your rights under California law.
This Privacy Policy describes how Reeves International Inc. (“Reeves,” “we”, “us” or “our”) processes personal information that we collect through our websites, www.reevesintl.com, www.breyerhorses.com, https://thebigdig.com/, https://paddockpals.breyerkids.com/, and any mobile applications or other digital properties that we own or control and that posts or links to this Privacy Policy (collectively, the “Website”), as well as through social media pages, our marketing activities and other activities described in this Privacy Policy.
European users: If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please read the Notice to EEA and UK users below in addition to this Privacy Policy for information about your personal information and your privacy rights.
Index
- Personal information we collect
- How we use your personal information
- How we share your personal information
- Your choices
- Other sites and services
- Security
- International data transfers
- Children
- Changes to this Privacy Policy
- How to contact us
- California privacy rights
- Notice to EEA and UK users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Website or otherwise includes:
- Contact data, such as your first and last name, email address, billing and mailing addresses, phone number, and company name, phone number, and address (if applicable).
- Account data, such as the username and password that you may set to establish an online account with us and any other information that you add to your account profile.
- Transactional data, such as information relating to or needed to complete your orders, including order numbers and transaction history.
- Communications data based on our exchanges with you, including when you contact us through the Website, social media, or otherwise.
- Research data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Payment data needed to complete transactions, including payment ID.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as social media platforms and other publicly available sources.
- Private sources, such as data providers and data licensors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Website, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages you viewed, how long you spent on a page, the website you visited before browsing to the Website, navigation paths between pages, information about your activity on a page, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Website.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Website delivery and operations. We may use your personal information to:
- provide and operate the Website and our business;
- personalize the Website, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Website;
- establish and maintain your user account;
- communicate with you about the Website and our business, including by sending Website/business-related announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience on the Website and our communications; and
- provide support for the Website, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Website and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business.
Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Your choices section below.
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interactions (including the data described in the automatic data collection section above) with the Website, our communications, and other online websites over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising by visiting our Cookie Notice.
Events, promotions, and contests. We may use your personal information to:
- administer promotions and contests;
- communicate with you about promotions or contests in which you participate; and
- contact or market to you after collecting your personal information at an event.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Website; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How we share your personal information
We may disclose your personal information to the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the Website or our business (such as information technology, customer support, email delivery, marketing, research and analytics).
Payment processors. Any payment card information you use to make a purchase on the Website is collected and processed directly by our payment processors, such as PayPal and FreedomPay. PayPal may use your payment data in accordance with its privacy policy, https://www.paypal.com/us/webapps/mpp/ua/privacy-full. FreedomPay may use your payment data in accordance with its privacy policy, https://corporate.freedompay.com/privacy-policy.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Reeves, financing of Reeves, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Reeves as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Your choices
In this section, we describe the rights and choices available to all users. Users who are located in the EEA or the UK can find additional information about their rights in the Notice to EEA and UK users below.
Access or update your information. If you have registered for an account with us through the Website, you may review and update certain account information by logging into the account.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may also opt-out of marketing-related emails or marketing-related mailings by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Cookies. For information about cookies employed by the Website and how to control them, see our Cookie Notice.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track”. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Website may contain links to third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions, nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in the EEA and the UK should read the important information provided in the Notice to EEA and UK users below about the transfer of personal information outside of the EEA and the UK.
Children
The Website is not intended for use by anyone under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us at breyerwebstore@reevesintl.com. If we learn that we have collected personal information through the Website from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Website after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Website and our business.
How to contact us
• Email: breyerwebstore@reevesintl.com
• Phone: (800) 413-3348
California privacy rights
This section applies only to California residents. It describes how we collect, use, disclose and share personal information of California residents in operating our business, and their rights with respect to that personal information. For purposes of this section, “Personal Information” means personal information protected by the California Consumer Privacy Act (as amended) (“CCPA”) but does not include data exempted from the scope of the CCPA.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.
- Information. You can request information about the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting, sharing and/or selling Personal Information; the categories of any Personal Information that we sold or disclosed for a business purpose; and the categories of any third parties with whom Personal Information was sold, shared or disclosed for a business purpose.
- Access. You can request a copy of the Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you.
- Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
- Opt-out. You can opt-out of the sharing of your Personal Information for interest-based advertising purposes and/or from the sale of your Personal Information for monetary or other valuable consideration (as applicable).
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.
How to Exercise Your Rights
- Right to information, access, correction, and deletion. You can request to exercise these rights by visiting [link to webform], calling us toll free at [(800) 413-3348, or via email to breyerwebstore@reevesintl.com.
- Right to opt-out of the “sale” or “sharing” of your Personal Information. You can request to opt-out of the “sale” or “sharing” of your Personal Information by clicking the Do Not Sell or Share My Personal Information link in the footer of this webpage. Your request to opt-out will apply only to the browser and the device from which you submit the request.
Identity verification. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into your account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email address used to make the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.
Authorized agents. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months:
- Sale and sharing of Personal Information. We have no actual knowledge that we have sold or shared the Personal Information of California residents under 16 years of age.
- Sensitive personal information. We do not use or disclose sensitive personal information (as that term is defined under CCPA) for purposes that California residents have a right to limit under the CCPA.
- Deidentified data. We do not to attempt to reidentify deidentified information that we derive from Personal Information except that we may do so to test whether our deidentification processes comply with applicable law.
- Retention. Our criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Privacy Policy, including complying with our legal obligations.
- Sources and purposes. We collect all categories of Personal Information from the sources, use them for the business purposes described in the Personal information we collect and How we use your personal information sections above, and disclose them for the business and commercial purposes described in the How we share personal information section above.
- Collection and disclosure. The chart below describes the Personal Information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose Personal Information for business purposes. The terms in the chart refer to the categories of information and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below. We may also disclose Personal Information to professional advisors, authorities and others, and business transferees as described above in the How we share personal information section above.
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Statutory category/Personal Information we collect |
Categories of third parties to whom we disclose the Personal Information for a business purpose |
Categories of third parties to whom we “sell” or “share” Personal Information |
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Identifiers · Contact data · Account data · Transactional data · Communications data · Research data · Marketing data · Third-party sources data
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· Service providers · Payment processors · Advertising partners · Business and marketing partners |
· Advertising partners
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California Customer Records (as defined in California Civil Code §1798.80) · Contact data · Account data · Communications data · Research data · Marketing data · Third-party sources data
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· Service providers · Payment processors · Advertising partners · Business and marketing partners |
· Advertising partners
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Commercial Information · Transactional data · Payment data · Communications data
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· Service providers · Payment processors · Advertising partners · Business and marketing partners
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· Advertising partners
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Internet or Network Information · Device data · Online activity data · Communication interaction data
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· Service providers · Advertising partners · Business and marketing partners |
· Advertising partners
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Inferences May be derived from any of the above categories
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· Service providers · Advertising partners · Business and marketing partners |
· Advertising partners
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Notice to EEA and UK users
General
Where this Notice to EEA and UK users applies. The information provided in this ‘Notice to European users’ section applies only to individuals located in the European Economic Area (EEA) or United Kingdom (UK) (i.e., “Europe” as defined at the top of this Privacy Policy).
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”)) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified. The personal information that we collect from and about you is described in greater detail in the section “Personal Information we collect”.
Controller. Reeves is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the How to contact us section above for our contact details.
Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:
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Our Representative in the EU. Our EU representative appointed under the EU GDPR is DataRep. You can contact them:
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Our Representative in the UK. Our UK representative appointed under the UK GDPR is DataRep. You can contact them:
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Country |
Address |
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Austria |
DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
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Belgium |
DataRep, Rue des Colonies 11, Brussels, 1000 |
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Bulgaria |
DataRep, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria |
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Croatia |
DataRep, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia |
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Cyprus |
DataRep, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus |
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Czech Republic |
DataRep, Platan Office, 28. Října 205/45, Floor 3&4, Ostrava, 70200, Czech Republic |
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Denmark |
DataRep, Lautruphøj 1-3, Ballerup, 2750, Denmark |
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Estonia |
DataRep, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia |
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Finland |
DataRep, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland |
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France |
DataRep, 72 rue de Lessard, Rouen, 76100, France |
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Germany |
DataRep, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany |
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Greece |
DataRep, Ippodamias Sq. 8, 4th floor, Piraeus, Attica, Greece |
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Hungary |
DataRep, President Centre, Kálmán Imre utca 1, Budapest, 1054, Hungary |
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Iceland |
DataRep, Kalkofnsvegur 2, 3rd Floor, 101 Reykjavík, Iceland |
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Ireland |
DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland |
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Italy |
DataRep, Viale Giorgio Ribotta 11, Piano 1, Rome, Lazio, 00144, Italy |
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Latvia |
DataRep, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia |
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Liechtenstein |
DataRep, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria |
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Lithuania |
DataRep, 44A Gedimino Avenue, 01110 Vilnius, Lithuania |
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Luxembourg |
DataRep, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg |
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Malta |
DataRep, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta |
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Netherlands |
DataRep, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands |
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Norway |
DataRep, C.J. Hambros Plass 2c, Oslo, 0164, Norway |
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Poland |
DataRep, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland |
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Portugal |
DataRep, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal |
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Romania |
DataRep, 15 Piaţa Charles de Gaulle, nr. 1-T, Bucureşti, Sectorul 1, 011857, Romania |
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Slovakia |
DataRep, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia |
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Slovenia |
DataRep, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia |
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Spain |
DataRep, Calle de Manzanares 4, Madrid, 28005, Spain |
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Sweden |
DataRep, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden |
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United Kingdom |
DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom |
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Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.
Our legal bases for processing your personal information described in this Privacy Policy are listed below.
- Where we need to process your personal information to deliver our Website to you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see How we use your personal information above.
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Purpose |
Categories of personal information involved |
Legal basis |
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Website delivery and operations |
· Contact data · Account data · Transactional data · Communications data · Payment data |
Contractual Necessity. |
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Research and development |
· Any and all data types relevant in the circumstances |
Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers. |
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Direct marketing |
· Contact data · Account data · Marketing data |
Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications. |
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Interest-based advertising |
· Device data · Online activity data · Location data |
Consent. |
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Events, promotions, and contests |
· Contact data · Account data · Communications data · Research data |
Legitimate Interests. We have a legitimate interest in promoting our operations and offering events, promotions, and contests for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws for events, promotions, and contests. |
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Compliance and protection |
· Any and all data types relevant in the circumstances |
Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety. |
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Further uses |
· Any and all data types relevant in the circumstances |
The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected. |
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information, we have collected about you, 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Other information
No obligation to provide personal information. You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Website to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our services to you. We will notify you if this is the case at the time.
No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Website, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Website.
No automated decision-making and profiling. As part of the Website, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.
Your rights
General. European data protection laws give you certain additional rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
- Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Exercising These Rights. To exercise any of these rights, please contact us using the contact details provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
- For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data processing outside Europe
We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Website, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
- Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US).
- However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.
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