Privacy Policy

Privacy Policy

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Solgaard Design, Inc. (“we,” “us,” “our”) respects your privacy and is committed to protecting the Personal Information we hold about you. This Privacy Policy explains our practices with respect to Personal Information we collect and process about you. This includes information we collect through, or in association with, our website with a home page located at levisantana.shop, our products and services that we may offer from time to time via our website, our related social media sites, or otherwise through your interactions with us (the website, products, services, and social media pages, collectively, the “Services”). 

Please review the following to understand how we process and safeguard Personal Information about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing Personal Information to us, you acknowledge that you have read and understand the practices contained in this Privacy Policy. This Privacy Policy may be revised from time to time, so please ensure that you check this Privacy Policy periodically to remain fully informed.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please see our Accessibility Statement (https://levisantana.shop/pages/accessibility-statement)

WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

When you purchase something from our store, as part of the buying and selling process, we collect the Personal Information you give us, such as your name, address, and email address.

When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.

HOW DO WE USE YOUR PERSONAL INFORMATION? 

We collect and process your Personal Information for the following business and commercial purposes: 

• Providing customer service, processing or fulfilling orders and transactions, verifying customer information, and processing payments.
• Marketing our products and services to you, including sending you messages about the products and services we offer, which may include special offers for products and services. 
• Communicating with you by email about products, services, order status, and information tailored to your requests or inquiries.  
• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
• As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and obtaining your consent.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your Personal Information to our service providers, as well as with government agencies or regulations when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others; and/or if you violate our Terms of Service 

We may also disclose your Personal Information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of our company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us about the Services is among the assets transferred.

SHOPIFY

Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.

Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.

Payment:
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express, and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

For more information, please see Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).

THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

Once you leave our store’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service (https://levisantana.shop/pages/terms-and-conditions) 

Links:
As a convenience, we may also reference or provide links to third-party websites and services. When you click on links on our store, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

Google Analytics:
We use Google Analytics to help us learn about who visits our site and what pages are being looked at. Such services may use cookies to help us analyze how users use our Services. You can find out more about how Google uses data when you use our Services by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).

Social media platforms:

If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (such as Instagram, Facebook, Twitter, or, YouTube) in connection with the Services, we may collect information that you share with us or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.

YOUR CHOICES

Consistent with applicable law, you may exercise the options described in this section regarding your choices with respect to communications from us. 

• Email: You may opt out of receiving marketing or other communications from us at any time through a given communications channel by following the opt-out link or other unsubscribe instructions provided in any email message received. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email.  Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

• Text Messages: By subscribing to text notifications you agree to receive recurring automated marketing messages at the phone number provided. Consent is not a condition of purchase. Reply STOP to unsubscribe. HELP for help. Msg & Data rates may apply. 

Postal Mail: If you do not wish to receive catalogs, coupons, and other promotional postal mail, please email us at [email protected] to opt-out.

• Cookies: If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of the Services may be affected. 

SECURITY

To protect your Personal Information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure. 

You can find more information about how Shopify protects your Personal Information here. 

RETENTION

We retain Personal Information to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.

COOKIES

"Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our site, the type of browser you are using, your Internet Protocol (IP) address, what pages on our site you visit and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Services. We may also use cookies to customize your use of the Services and for other purposes to make your visit more convenient or to enable us to enhance our Services. We use cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS. Here is a list of cookies that we use. We’ve listed them here so you that you can choose if you want to opt-out of cookies  by visiting https://levisantana.shop/pages/privacy-center.

• _session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).
  
  
• _shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits
  
  
• _shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer.
  
  
• cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.
  
  
• _secure_session_id, unique token, sessional
  
  
• storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.
  
  
• PREF, persistent for a very short period, Set by Google and tracks who visits the store and from where

SMS

By signing up via text, you agree to receive recurring automated promotional and personalized marketing text messages (e.g. cart reminders) from Solgaard at the cell number used when signing up. Consent is not a condition of any purchase. Reply HELP for help and STOP to cancel. Msg frequency varies. Msg and data rates may apply. View Terms & Privacy

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

YOUR RIGHTS 

Depending on where you reside, you may have certain rights regarding the collection and processing of your Personal Information. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Policy.

• Residents of California, please see our California Privacy Rights Notice 
• Residents of Virginia, please see our Virginia Privacy Rights Notice 

• Residents of the EU, UK and Switzerland, please see our EEA, UK, and Switzerland Privacy Rights Notice 

• Residents of Nevada

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by emailing us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

• Residents of Canada

Residents of Canada are permitted to request and obtain from us information respecting the existence, use, and disclosure of their Personal Information as well as access to that information (subject to certain exceptions pursuant to applicable laws). Without limiting the above, residents of Canada will, upon request:

• Be informed of whether we hold Personal Information about you;
• Be provided with an account of third parties to which we have disclosed your Personal Information; 
• Be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate; and 
• Be provided with information about our policies and practices with respect to the management of Personal Information, including: the name or title, and address, of the person who is accountable for our privacy policies and practices; the means of gaining access to Personal Information; a description of the type of Personal Information held by us, including a general account of its use; a copy of any brochures or other information that explain our policies, standards, or codes; and what Personal Information is made available to related organizations. 

INTERNATIONAL USE 

Your Personal Information will be stored and processed in the United States. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your Personal Information in, the United States, which may have different data protection rules than in your country, and Personal Information may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States. 

 CHILDREN’S PRIVACY

Children under 16 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 16. By using the Services, you represent that you are that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so .

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this Privacy Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. Your continued use of the Services after the effective date of the revised Privacy Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different from what was stated at the time your Personal Information was collected.

QUESTIONS AND CONTACT INFORMATION

If you have any questions or simply want more information about this Privacy Policy, please contact our Privacy Compliance Officer at [email protected] or by mail at:
Solgaard Design, Inc.
ATTN: Privacy Compliance Officer
270 Lafayette Suite 902

NY NY 10012

California Privacy Rights Notice

These provisions apply only to California consumers and supplement this Privacy Policy. The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws,” provide California consumers with specific rights regarding their Personal Information. This California Privacy Notice describes your rights under the California Consumer Privacy Laws, explains how you may exercise your rights, and provides an overview on the types of Personal Information we collect.

California Consumer Privacy Laws provide you with the following rights:

• Right to know. You have the right to know what categories and specific pieces of Personal Information we collect about you, the sources from which we collect Personal Information, our business or commercial purpose for the collection, use, and sharing of your Personal Information, and any categories of third parties to whom we sell or with whom we share your Personal Information.  
• Right to data portability. You have the right to request a copy of Personal Information we have collected and maintained about you in the past 12 months. California Consumer Privacy Laws allow you to request your information from us up to twice during a twelve (12) month period.  We will provide our response in a readily usable format, which is usually electronic.
• Right to delete. You have the right to request that we delete the Personal Information that we have collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our vendors to:
• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
• Comply with a legal obligation.
• Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
• Right to opt out of selling or sharing. You have the right to opt out of the sale or sharing of your Personal Information, along with the right to opt in to the sale of such information. However, at the time this Privacy Policy was last updated, we do not sell Personal Information; and (2) we do not share Personal Information for the purpose of cross-context behavioral advertising. 
• Right to correct. You have the right to request the correction of any Personal Information we maintain about you. 
• Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your California privacy rights. Unless permitted by the California Consumer Privacy Laws, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services. 
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise your California privacy rights, please submit a request to us by emailing us at [email protected] or calling us at 917 628 7632.

Verification of Your Identity

After you submit a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request.

Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your personal information. If you are making a request as the authorized agent of a California consumer, we will also ask you to submit additional information (such as your name, contact information, relationship to consumer making the request, copy of written authorization, and additional supporting information) so that we may establish that you have been authorized in writing by the consumer to act on such consumer’s behalf

Our Response Time to Your Request

We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the California Consumer Privacy Laws allow us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond.

Personal Information We Collect

In the past 12 months, we have collected the categories of Personal Information described below for the business or commercial purpose(s) indicated. Depending on your level of interaction with us, we may not have collected your Personal Information from all of the categories.

Category	Purpose(s)	Disclosed to:
Identifiers, such as name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, device, browser, email address, account name, or other similar identifiers	optimally deliver our existing products and services	3rd party services such as Shopify, Klaviyo, Google, Facebook
Commercial information, such as records of products or services purchased; purchasing or consuming histories or tendencies	optimally deliver our existing products and services	Shopify, Klaviyo, Google, Facebook
Internet or other similar network activity information, such as browsing history, search history, information regarding consumer’s interaction with a website, application, or advertisement	optimally deliver our existing products and services	Shopify, Klaviyo, Google, Facebook

California “Shine the Light”

Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of Personal Information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at [email protected] . If you do not want your Personal Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at [email protected].

VIRGINIA PRIVACY RIGHTS NOTICE

The Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia consumers with specific rights regarding their Personal Information. This section describes your rights under the VCDPA and explains how you may exercise these rights. We will also apply similar VCDPA rights to residents of other U.S. states with similar laws to which you and we are both subject.

The categories of Personal Information we process, our purposes for processing your Personal Information, the categories of Personal Information that we share with third parties and the categories of third parties with whom we share it are detailed above in our Privacy Policy. 

Certain rights that you may have concerning your Personal Information are set forth in our Privacy Policy. The VCDPA provides you with the following additional rights:

• Right to know. You have the right to know whether we process your Personal Information and to access such Personal Information. 
• Right to data portability. You have the right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means. You may request such Personal Information up to twice annually, subject to certain exceptions. 
• Right to delete. You have the right to delete Personal Information that you have provided by or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception to this right set forth in the VCDPA. Additionally, if you request deletion of your Personal Information and we have obtained such information from a third-party source, we may retain such data by keeping a record of the deletion request and the minimum data necessary to ensure that your Personal Information remains deleted from our records and that such retained data is not used for any other purpose, or we may opt you out of the processing of such Personal Information for any purpose except for those allowed under the VCDPA.
• Right to opt out of selling or sharing. You have the right to opt out of the processing of the Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As of the latest date of the Privacy Policy, we do not process Personal Information for the purposes of targeted advertising, sell your Personal Information in exchange for monetary consideration, or engage in profiling decision based on your Personal Information that produce legal or similarly significant effects concerning you.
• Right to correct. You have the right to correct inaccuracies in the Personal Information we collect from you, taking into account the nature of the Personal Information and the purposes for which we process it. 
• Right to nondiscrimination. You have the right not to receive discriminatory treatment by us for the exercise of your Virginia privacy rights. Unless permitted by the VCDPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services. 
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

To exercise the rights described above, please submit a request to us by emailing us at [email protected] or calling us at 917 628 7632.

Verification of Your Identity 

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify using reasonably commercial efforts that the consumer submitting the request is the same individual about whom we have collected Personal Information, then we are not required to comply with the request; we may contact you for more information reasonably necessary to authenticate the request, but ultimately we may not be able to meet your request.

Only you may make a verifiable request related to your Personal Information. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s Personal Information, we may ask you to submit reliable proof of your identity.

Our Response Time to Your Request

We will make every effort to respond to your request within forty-five (45) days from when you contacted us. If you have a complex request, the VCDPA allows us up to ninety (90) days to respond. We will still contact you within forty-five (45) days from when you contacted us to let you know we need more time to respond and the reason for the extension.

Your Right to Appeal

If we decline to take action regarding a request that you have submitted, we will inform you of our reason for declining to take action and provide instructions for how to appeal the decision. In the event that we do not respond to a request that you make pursuant to one of the privacy rights set forth in this section, you have the right to appeal our refusal to take action within a reasonable period of time after you receive our decision. Within 60 days of our receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact the Attorney General to submit a complaint.

European Economic Area / United Kingdom / Switzerland Privacy Rights

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

Legal Basis

We will only use your Personal Information, as that term is defined under the General Data Protection Regulation (“GDPR”), when the law allows us to. Most commonly, we will use your Personal Information in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where you have consented to a certain use of your Personal Information.
• Where we need to comply with a legal or regulatory obligation.

To the extent permitted under applicable laws, we will also process, transfer, disclose, and preserve Personal Information when we have a good faith belief that doing so is necessary. 

Data Controller

Solgaard Design, Inc. is the data controller of all Personal Information collected through our Services.

If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance. If you have a complaint, please contact our privacy manager by emailing [email protected] .

Provision of Personal Information and failure to provide Personal Information

Where we need to collect Personal Information by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of Personal Information from third-party sources

We may obtain Personal Information and other information about you from public sources and through our third-party partners who help us provide our products and services to you. 

Withdrawing your consent

If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time by contacting us at [email protected].

Data Transfer

We may transfer Personal Information from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give Personal Information the same protection it has in Europe. For more information about how we transfer your data, please contact us at [email protected] .

Use of your Personal Information for marketing purposes

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising:

• Promotional offers from us: We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have consented to our use of your Personal Information for marketing purposes.

Data Subject Rights

If you are situated in the European Union, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to: 

• Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove 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 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 which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

To exercise your rights under the GDPR, please contact us at [email protected]. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your Personal Information. This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more Personal Information from you than we currently have.