California Notice at Collection/State Law Privacy Rights: See the State law privacy rights section below for important information about your rights under applicable state privacy laws.
This Privacy Policy describes how Foo Monk, LLC ("
Instantly," "
we", “
us” or "
our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, and other activities described in this Privacy Policy (collectively, the “
Service”)).
Instantly may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.Instantly provides a platform designed to help its enterprise customers scale their email outreach campaigns. For platform-processing activities, we act on our relevant customer’s behalf and this Privacy Policy does not apply to personal information processed in this context. Our use of personal information that we process on the relevant customer’s behalf is based on the instructions that we receive from the relevant customer.
For example, the management of email validity and deliverability (e.g., invalid email addresses, bounced emails) is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a customer, please direct your concerns to that enterprise customer. Instantly also provides a business representative-to-business representative (“B2B”) lead database.
Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, familial or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise customer and not their individual capacities.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “
Europe” or “
European” and should be understood accordingly) below.
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
State privacy rights notice
Notice to European users
Personal information we collect
We may collect personal information from or about you from a variety of sources. Below, we describe the various manners in which we may collect such personal information. We may combine your personal information that we obtain from various sources.
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
Demographic data, such as your city, state, country of residence, and postal code.
Account data,
such as the username and password that you may set to establish an online account on the Service, information about where you found us, the email address(es) from which you conduct the outreach campaigns, and any other information that you add to your account profile.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
User-generated content data, such as reviews, comments, questions, messages and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Financial data, such as your financial account numbers or payment card information, including corporate payment card information.
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 obtain personal information about you from other sources, such as:
Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Private sources, such as data providers (including licensors) and social media platforms (such as Meta).
Marketing partners,
such as joint marketing partners.
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 Service, our communications and other online services. The information collected automatically may be combined or associated with information collected from other sources. The information collected automatically may include:
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 (including identifiers used for advertising purposes), 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 or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, 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, text 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. 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 Service.
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:
Service delivery and operations. We may use your personal information to:provide, operate and improve the Service and our business;personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;establish and maintain your user account on the Service;enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;understand your needs and interests, and personalize your experience with the Service and our communications; andprovide support for the Service, 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 Service 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 compile, derive, and otherwise process de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.
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 Opt-out of marketing
section below.
Interest-based advertising.
Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services 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 in the Your choices section of our Cookie Notice.
Service improvement and analytics.
We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
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 Service; 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.
Retention. We generally retain personal information to fulfill 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 fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as 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 may either delete it, anonymize it, or isolate it from further processing.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates.
Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties
that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics).
Payment processors.
Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
Advertising partners.
Third-party advertising companies for the interest-based advertising purposes described above.
Subscribers and other private parties. We may share your personal information with subscribers and others to our Services who purchase personal information from us through our lead-generation services. We do not control how our subscribers and other private parties may use your personal information. In addition certain User generated content data may be publicly displayed and include your personal information. For example, when you leave a comment on our website, your name may be publically displayed with your comment.
Warmup Pool Participants.
When you enroll in our “email warmup” service, your personal information, such as your name, email address and contact information as displayed in your email signature, may be shared with other participants in our “email warmup service.” We do not control how these participants and other private parties may use your personal information.
Data Providers. We may share your personal information with data providers; for example, in an effort to maintain accurate information about you in our and our data providers’ databases. We do not control how these data providers may use your personal information.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
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 Instantly, financing of Instantly, 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 Instantly 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 California, and Europe can find additional information about their rights below.
Access or update your information. If you have registered for an account with us through the Service, 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, or 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 and other tracking technologies. For information about cookies and other tracking technologies employed by the Service and how to control them, see our Cookie Notice.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
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” signals. 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 Service may contain links to 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. 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 Europe should read the important information provided below about transfer of personal information outside of Europe.
Children
The Service is not intended for use by anyone under 18 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. If we learn that we have collected personal information through the Service 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 Service 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 Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
Email:
[email protected]
Mail: 30 N. Gould St., Ste. R, Sheridan, Wyoming, 82801, United States
Phone: +1 657 242 8111
State privacy rights notice
Except as otherwise provided, this section applies to residents of California (collectively the “
State Privacy Laws”) to the extent it has privacy laws applicable to us that grant its residents the rights described below.This section describes how we collect, use, and share Personal Information of California residents and the rights California residents may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all individuals and that if you are not a resident of California, you may not be able to exercise these rights. In addition,
we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.
For purposes of this section, the term “
Personal Information” has the meaning given to “personal data”, “personal information” or other similar terms in the applicable State Privacy Laws and does not include information exempted from the scope of the State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply instead of this section.
Your privacy rights. The State Privacy Laws may enable residents of the relevant states with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months: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 and/or selling Personal Information.The categories of third parties with which we share Personal Information.The categories of Personal Information that we sold or disclosed for a business purpose.The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out.
Opt-out of certain processing for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
Opt-out of profiling/automated decision making. You can opt-out of automated processing or profiling performed on personal information to evaluate, analyze, or predict personal aspects related to a person's economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
Opt-out of other sales of personal data. You can opt-out of other sales of your Personal Information.
Opt-in. While we do not knowingly collect the Personal Information of individuals younger than 18, if we know that you are 13-15 years of age, we will ask for your affirmative authorization to sell your Personal Information or share your Personal Information for targeted advertising purposes before we do so.
Limit processing of Sensitive Personal Information. We do not knowingly use sensitive Personal Information, as defined by applicable State Privacy Laws, other than for a purpose which is necessary to perform the services.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.
Exercising your right to information/know, access, appeal, correction, and deletion. You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion at
LINK, calling us toll free at 1-866-467-8688 Service Code 1974#, or via email to
[email protected].
Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. You can by submit requests to opt-out of tracking for targeted advertising purposes or other sales of Personal Information here:
LINK, or via email to
[email protected] or via phone by calling 1-866-467-8688 Service Code 1974#. We sell or share PI the following categories of PI with subscribers, other private parties and data providers: contact data; demographic data; communications data; transactional data; marketing data; user-generated content data; device data, online activity data; communication interaction data; and data derived from the above.
Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law. Under some State Privacy Laws, you many enable an authorized agent to make a request on your behalf upon. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Personal information that we collect, use and disclose. We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
Contact data
CCPA statutory category: Identifiers; Commercial information; California customer recordsSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers and other private parties; Data providers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers and other private parties; and Data Providers.
Demographic data
CCPA statutory category: Identifiers; Commercial information; California customer recordsSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers and other private parties; Data providers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers and other private parties; and Data Providers.
Account data
CCPA statutory category: Identifiers; Commercial information; California customer recordsSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising).
Communications data
CCPA statutory category: Identifiers; Commercial information; California customer records; Internet or network informationSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: None.
Transactional data
CCPA statutory category: Identifiers; Commercial information; California customer records; Financial informationSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: None.
Marketing data
CCPA statutory category: Identifiers; Commercial information; California customer recordsSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: None.
User-generated content data
CCPA statutory category: Identifiers; Commercial information; California customer recordsSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers and other private parties; Data providers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers and other private parties; and Data Providers.
Financial data
CCPA statutory category: Identifiers; Commercial information; California customer records; Financial informationSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: None.
Other data
CCPA statutory category: Identifiers; Commercial information; California customer records; Inferences; Protected classificationsSources: You; Third-party sourcesBusiness/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protectionThird parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers and other private parties; Data providers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees.Third parties to whom we
“sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers and other private parties; and Data Providers.
Shine the light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to [EMAIL]. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email
[email protected].
Notice to European users
General
Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (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., information about individuals from they are either directly identified or can be identified.
Controller. Instantly is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the
EU GDPR and the so-called ‘
UK GDPR’ (as and where applicable, 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:
Our Representative in the EU. Our EU representative appointed under the EU GDPR is
EDPO. You can contact them:
By using EDPO’s
online request form.
By postal mail to: Avenue Huart Hamoir 71, 1030 Brussels, Belgium
Our Representative in the UK. Our UK representative appointed under the UK GDPR is
EDPO. You can contact them:By using EDPO’s
online request form.By postal mail to: 8 Northumberland Avenue, London WC2N 5BY, United KingdomOur 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 perform a contract, we are about to enter into or have entered into with 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, in a table format, 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’
Purpose
Categories of personal information involved
Legal basis
Service delivery and operations
Contact data
Account data
Communications data
User-generated content data
Device data
Financial data
Transactional data
Contractual Necessity
Research and development
Any and all data types relevant in the circumstances
Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Service and how we use Personal Information is as un-privacy intrusive as possible.
Service improvement and analytics
Contact data
Account data
Device data
Online activity data
Communication interaction data
Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.
Consent, in respect of any optional cookies used for this purpose.
Direct marketing
Contact data
Account data
Communications data
Marketing data
Communication interaction data
Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation 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.
Interest-based advertising
Device data
Online activity data
Consent
Compliance and protection
Any and all data types relevant in the circumstances
Compliance with Law.
Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
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.RetentionWe 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 info
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 services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, 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 services.
No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.
Your rights
General.
European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take 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 good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – 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.
Exercising These Rights. You may submit these requests by email to
[email protected] or our postal address 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.
Your Right to Lodge a Complaint with your Supervisory Authority.
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 European Economic Area – 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 is below:The Information Commissioner’s OfficeWater Lane, Wycliffe HouseWilmslow - Cheshire SK9 5AFTel. +44 303 123 1113
Website:
https://ico.org.uk/make-a-complaint/
Data Processing outside Europe We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe. It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws. 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 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).
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 U.S., see above). 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 authorise 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.
