Last Modified: December, 2020
Information We Receive
In the course of your use of the Services, we obtain the information about you described below. We may need to collect this information to provide you with services or information you request, or to facilitate commercial engagements with you. If you do not provide such information, we may not be able to provide services or information to you, or enter commercial engagements with you. We will only collect information about you that is necessary for one or more of our legitimate business purposes, or that is required by law. We collect the following information:
Signing Up for Services; User Information
- Information you provide prior to any registration process, such as your email when you provide it to us;
- Information that you provide during any registration process, including in connection with a co-branded offer (such as your name and email address), when you call or email us (for support or otherwise) or when you use our products or services.
Use of Services, Website Visits and Support
- Data relating to your online activity on our website with respect to our Services, including the following:
- IP address (on an anonymized basis)
- browser type and version
- geographic location
- pages you view on our website
- how you got to our Services and any links you click on to leave our Services
- when you update your information, communicate with us, or order new Services
- metadata about your use of our Services and the communication that you send in-site
- your interactions with any videos we offer
- issues you encounter requiring our support or assistance
- any device or other method of communication you use to interact with the Services
- We use various technologies to collect and store information when you use our Services, and this may include sending one or more cookies or anonymous identifiers to your device. We may store the data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.
- While using our Services, you may provide feedback to us regarding the Services. We will collect any information you provide as part of this feedback and use it to improve the Services for you and other Users and to be better informed about our user base overall for the purpose of understanding societal interests at an anonymous, metadata level.
- Information that is publicly available; and
- Information you consent to us receiving from third parties.
How We Use Your Information
We will never sell your data or private information to others. We have a legitimate interest in running a successful and efficient business and in providing you with Services and useful content, and we use the information we collect, both on its own and combined with any other information we collect about you, for the following purposes:
- To provide the requested Services to you;
- To provide you with useful content;
- To ensure the proper functioning of our Services
- To offer and improve our Services;
- To provide you with requested information or technical support;
- To facilitate your movement through our website or your use of our Services;
- To do a better job of advertising and marketing our Services (our use of your information to do this is performed with your consent where required by applicable law);
- To diagnose problems with our servers or our Services;
- In connection with our security and compliance programs;
- To administer our websites;
- To communicate with you;
- To target prospective customers with our products or services (such targeting is only performed with your permission where your consent is required by applicable law);
- To assist us in offering you a personalized experience or otherwise tailor our Services to you; and
We also use the information we receive in aggregated and anonymized formats to produce reports on trends and statistics, such as mobile search trends, email open rates by industry, campaign best practices or the number of Users that have been exposed to, or clicked on, our websites or evaluated or purchased our Services.
[We do not collect payment information, including but not limited to credit card data. You will be directed to a third-party site to process any payments you make to Pondr.]
We do not use your personal data for the purposes of automated decision-making or profiling. If we do so in the future, we will inform you of any such processing and provide you with an opportunity to object.
You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at firstname.lastname@example.org. Some communications from us are considered transactional or service communications (for example, important account notifications and content reaction correspondence), and your account(s) for our Services are provided to you upon the condition that you receive these communications from us. You must cancel your account(s) for our Services if you do not wish to receive any transactional or service communications. To cancel your account(s), please follow the instructions found in the Terms of Service. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.
We may contact you by telephone, with your consent where applicable, in order to provide our Services.
Information from Third Parties
If an account or profile was created without your knowledge or authorization, please contact customer support at the brand on which the account or profile is located to request removal of the account or profile.
RETENTION OF PERSONAL INFORMATION
We retain your personal information to provide Services to you and as otherwise necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will retain your personal information for no more than one month following the date on which you terminate your use of the Services, unless we are otherwise required by law or regulation to retain your personal information for longer.
Where the European Union’s General Data Protection Regulation 2016/679, or GDPR, applies, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. While we are a US-based service and not generally subject to GDPR, we endeavor to materially follow the guidelines of GDPR. We set out below an outline of those rights and how to exercise rights under GDPR. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. Please note that for each of the rights below we may have valid legal reasons to refuse your request; in such instances we will let you know.
You have the right to know whether we process personal information about you, and if we do, to access personal data we hold about you and certain information about how we use it and who we share it with.
You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
You may request that we erase the personal information we hold about you in the following circumstances:
- where you believe it is no longer necessary for us to hold the personal information;
- we are processing it on the basis of your consent and you wish to withdraw your consent;
- we are processing your data on the basis of our legitimate interest and you object to such processing;
- you no longer wish us to use your data to send you marketing; or
- you believe we are unlawfully processing your data.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please send your request by e-mail to us at email@example.com.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:
- you believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
- we wish to erase the personal information as the processing we are doing is unlawful but you want us to simply restrict the use of that data;
- we no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; or
- you have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.
You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.
Please send any objections to us by e-mail at firstname.lastname@example.org
Withdrawal of Consent
Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by e-mailing us at email@example.com
THIRD PARTY LINKS AND INFORMATION COLLECTION AND USE BY OUR USERS
Some of our Services provide links to other websites. Because we do not control the information policies or practices of these third party sites, you should review their privacy policies to learn about how they collect and use personal information.
Our Services are not directed to persons under 13. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without such parent or guardian’s consent, he or she should contact us. If we become aware that a child under 13 has provided us with personal information, we will delete such information from our files.
In order for us to provide the Services to you, your personal information will be transferred to, and stored at/processed in the United States. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
For transfers of personal information within our corporate family, such transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU.
For transfers of data to third parties, such transfers will either (i) be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC and 2010/87/EU; or (ii) rely on the EU-US Privacy Shield Framework.
In the event that you wish to make a complaint about how we process your personal information, please contact us at firstname.lastname@example.org and we will try to deal with your request.
NOTIFICATION OF CHANGES