1. CONTACT INFORMATION AND BASIC PERSONAL DETAILS
○ For example : your full name, phone number, postal address, e-mail address, zip code.
○ How we use it : We use this information to:
- communicate with you, including sending statements and invoices, communications, news, alerts and marketing communications;
- deal with enquiries and complaints made by or about you relating to the Services;
- authentication purposes; and
- create customer accounts and operate, maintain and provide to you the features and functionality of the Services.
○ Legal basis for the processing :The processing is necessary for:
- the performance of a contract and to take steps prior to entering into a contract;
- our legitimate interests, namely administering the Services, for marketing purposes and communicating with users; and to comply with certain legal obligations; and
- to comply with certain legal obligations.
2. WEBSITES, BUSINESS AND MARKETING INFORMATION
○ For example : company websites, IP address, current email list size, e-commerce software in use, email marketing software, product usage information, demographic data, data about customer’s 3rd party services, other business information (Facebook ad spend, status of business, industry, business goals).
○ How we use it : We use this information to:
- operate, maintain and provide to you the features and functionality of the Services;
- provide you with Services to deal with any requests or inquiries you may have and to carry out the Company’s obligations arising from any contracts it has entered into with you;
- ensure that content is presented in the most effective manner; and
- determine relevant advertising / marketing activities.
○ Legal basis for the processing : The processing is necessary for:
- the performance of a contract and to take steps prior to entering into a contract; and
- our legitimate interests, namely administering the Services and for marketing purposes.
3. PAYMENT INFORMATION
○ For example : your credit card information, account information, billing address, shipping address and related information.
○ How we use it : We use this information to facilitate payment for use of the Services and to detect and prevent fraud.
○ Legal basis for the processing : The processing is necessary for the performance of our contract with you and our legitimate interests, namely the detection and prevention of fraud.
4. CORRESPONDENCE AND COMMENTS
○ For example : comments recorded when you contact us directly, e.g. by email, phone, mail, when you post on message boards, blogs or complete an online form or provide quality survey input.
○ How we use it : To address your questions, issues and concerns and improve the Services, to determine products and services that may be of interest to you and to send you news, alerts and marketing communications in accordance with your marketing preferences.
○ Legal basis for the processing : The processing is necessary for our legitimate interests, namely communicating with users and for marketing purposes.
5. ALL PERSONAL INFORMATION SET OUT ABOVE
○ How we use it : We will use all the personal information we collect to prevent and detect fraud, to operate, maintain and provide to you the features and functionality of the Services, to communicate with you, to monitor and improve the Services, our Websites and business, and to help us develop new products and services.
○ Legal basis for the processing : The processing is necessary for our legitimate interest, namely to administer and improve the Services, our Website, our business and develop new services.
6. CATEGORIES OF POTENTIAL RECIPIENTS OF DISCLOSED PERSONAL INFORMATION
As required in accordance the uses of personal information outlined above, we may share and disclose your personal information with the following categories of recipients:
○ Group of companies :Personal information may be disclosed to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy.
○ Service providers and advisors : Personal information may be disclosed to third party vendors and other service providers that perform services for us, on our behalf, which may include providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. Your personal information is never transferred to any third-party for the purposes of re-marketing to you.
○ Partners : We may disclose your personal information to partners of the Company, so that they can communicate with you (whether by email, post or otherwise) and provide you with promotional materials and additional information about their products, services, contests, promotions and special offers that may be of interest to you, or and use that information subject to and for other purposes contemplated by this Policy.
○ Purchasers and third parties in connection with a business transaction : Personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
○ Law enforcement, regulators and other parties for legal reasons : Personal information may be disclosed to a government or regulatory entity that has asserted its lawful authority to obtain the information or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Services or Websites; and/or (c) exercise or protect the rights, property, or personal safety of the Company, our customers or others.