This Policy is currently in effect and was last updated on April 05, 2019. We reserve the right to unilaterally modify this privacy statement at any time, so please review it frequently. If we make material changes to this Policy we will notify you prior to making the changes on our homepage and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
When you use our Services, you may be required to provide personal information (additional details below). Collection of certain Personal Data (particularly your payment details and contact information) is required for many of our products and services and if you fail to supply such Personal Data, we may be unable to deliver you the products and services in full.
We may collect the following Personal Data:
We do not store or collect your payment details such as credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information. Payments are processed through third-party payment processors (such as Apple Store in-App Payments, and Google Play in-App Payments) whose use of your personal information is governed by their privacy policies.
We will collect Personal Data from you directly to the greatest extent possible. However, we may also collect Personal Data from other third parties including:
As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically-collected data to other information we collect about you. Some information is also collected automatically every time you visit our Website (e.g., cookies and conversion beacons). We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Website, tracking users’ movements around the Website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. We currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track”, please visit https://allaboutdnt.com for more information.
We may also partner with other third parties from time to time to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this Website and other sites to provide you advertising based upon your browsing activities and interests.
We also use Conversion Beacons (small, simple snippet of HTML code) inserted in the source of the designated website pages. Conversion Beacon technology works by leveraging industry standard browser-based cookie technology and simple standard HTML coding. Email recipients who receive a Conversion Beacon enabled email message will receive a small unique cookie that is stored in their browser session. This unique cookie is later used to connect the email recipient with the subsequent recipient activity on the client website. The purpose of tracking the activity is to better understand the email flow of our subscribers and to measure the effectiveness of ads. For this reason, our Conversion Beacons are tied to personally identifiable information (email address).
When you use our Services or visit our Website, you provide us with your implied consent to use your Personal Data to fulfill your request. We may also use your Personal Data for the following purposes:
We may use Personal Data for marketing and promotional purposes, including (i) for sending or showing you updates on latest news, offers and promotions in connection with our products and services (and the products and services of our group companies and third parties) (ii) for sending or showing you joint marketing offers about our services and packages, contests and sweepstakes, and ancillary services; or (iii) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our Website.
We may also use Personal Data to analyze our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to our customers. This may involve us combining Personal Data that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about our other customers in order to derive these insights and establish market trends.
We may communicate marketing and promotions to you online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.
You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by following the opt-out instructions contained in the relevant communications or updating your email subscriptions.
We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us at our Address set out below.
Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about your orders with us and any other services that we provide to you. Where you are an account holder, you will also continue to receive administrative emails, account and/or order summaries and updates to our services.
When you use our Services you are added to our email list that will be used to contact you occasionally with offers that we feel will be of interest to you. If you do not want us to contact you with offers, you may withdraw your consent at any time. If you later change your mind it is just as simple to opt back into the email offers of your choice. In addition, all emails sent to you by us contain simple instructions telling you how to "unsubscribe."
Our Services are not addressed to anyone under the age of majority in the jurisdiction where they reside (“Children”). We do not knowingly collect Personal Data from Children. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children we will take steps to delete that Personal Data from our systems.
We only collect Personal Data to the extent necessary to fulfill the purposes set out in section 3 above.
If a third party, including a family member, friend, or work colleague seeks to interact with us on your behalf, that party will be asked to provide us with the same Personal Data that we would normally collect from you directly in order to provide the Services. Unless and until we are advised otherwise, we consider that such third party has your consent and authorization to provide us with your Personal Data, to receive promotional and service emails, and to make orders (and changes thereto) on your behalf in accordance with this Policy. Please note that the collection, use and disclosure of your Personal Data by a third party is subject to your dealings with them and any applicable privacy policies and practices they may have.
If a third party who has used our Services on your behalf or who otherwise has your full name, contact information and login information and contacts us and seeks information related to the Services we provide you or wishes to make changes to it, we will disclose your order information and allow such third party to make changes as we will conclude that you have given them your consent to do so. If you do not want an individual to be able to obtain information on or make changes to your profile or the manner in which Services are provided to you, you should not share your login details with them.
If you provide us with information about other individuals, you must tell those individuals and let them know where they can find a copy of this Policy.
We do not sell your Personal Data to third parties. Other than as set out herein, we will not use or disclose your Personal Data for purposes other than those for which it was collected without your explicit consent or as required by law.
We use contractual and other means to ensure that your Personal Data is afforded protection that meets the requirements of privacy legislation whenever one of our third party service providers is used to perform services on our behalf, including without limitation, services relating to information technology, marketing, data processing and storage, research, conducting surveys and customer relations. In certain circumstances, we may disclose your Personal Data to third parties as follows:
As indicated above, there may be instances where we may share your Personal Data with third-party companies. If you do not want us to share your Personal Data with these third parties, contact us at our Address provided below.
We will retain your Personal Data for as long as is necessary for the purpose(s) for which it was collected and any other permitted related purpose (for example where we are required to retain Personal Data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our retention periods may vary depending on the purposes for which your Personal Data was collected. Once your Personal Data is no longer needed, it is either irreversibly anonymized (and the anonymized Personal Data will be retained) or securely destroyed.
We will take reasonable efforts to ensure your Personal Data is accurate, complete and current. However, we will not routinely update your Personal Data unless it is necessary to fulfill the purposes set out in section 3.
When you use our Services or create an account with our Website, if applicable, you can ensure that the Personal Data we hold is accurate and up to date. To help us do this, you may wish to notify us of any changes to your Personal Data.
No data transmission over the internet, a website, mobile application or via email or other message services can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, organizational and technological safeguards to protect your Personal Data in accordance with the requirements of data protection legislation.
All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using Personal Data and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, we ask you not to share that password with anyone.
Personal Data is encrypted as it travels over the internet. Depending on your web browser you may see a secure webpage indicator. The use of Secure Socket Layer protocol (SSL) allows all Personal Data, such as your payment card number, to be encrypted as it travels from your computer to our order system. Once received, the information is unencrypted and processed in the same way as a payment card transaction placed via the telephone.
We treat your Personal Data as strictly confidential, and we have taken the appropriate technical and organizational security measures against loss or unlawful processing of this information. To this end, we use several security techniques including secure servers, firewalls, and encryption, as well as a physical safeguard of the locations where data is stored. If you have any questions about the security of your Personal Data, you can contact us at our Address set out below.
Should you have any questions regarding this Policy or concerns with respect to our compliance with the requirements of applicable privacy legislation, you may contact us at the following address (our “Address”):
With certain limited exceptions, you have a right to access your Personal Data that we hold, including how we have used or are using your Personal Data and whether we hold or process any of your Personal Data on behalf of a third party. To request this information, please contact us in writing at our Address provided above. We will endeavour to provide any help that you need to prepare a request for access to your Personal Data. Part of this process may involve us requesting you to supply enough information to enable us to account for the existence, use and disclosure of the Personal Data.
We will respond to your request within a reasonable timeframe and will notify you if we are unable to respond to your request within thirty (30) days. If we are unable to provide you with your Personal Data, we will explain our reasons for refusing access. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
You have the right to raise a complaint about our processing with the data protection regulator in your jurisdiction. In Canada, this is the Office of the Privacy Commissioner of Canada (“OPC”). The OPC can be reached toll-free at (800) 282-1376.