Introduction and Definition
We are committed to your privacy recognising its importance and your need for security. Privacy is anyway a matter of trust.
Personally Identifiable Information (PII). We acquire PII that may include, in certain contexts, your name, address, postcode, email address, and telephone number(s), which you yourselves have willingly shared on the website or elsewhere with us either directly or indirectly regardless of the platform or means. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII, because it could be used to identify an individual or a Device if it were combined with other identifying information (i.e. your IP address).
Sensitive PII. On certain occasions, for instance when registering for an event or contributing to a fundraiser, you may provide a credit, debit, or payment account number, or other payment information, which could be recognised as more sensitive than other PII. We generally do not request other Data that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personal health information, or government-issued identification numbers (e.g., social security number, drivers’ license number, or passport number). Nonetheless, we reserve the right to do so when such Data is necessary to offer you certain services.
Anonymous Data. Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.
How we acquire your data
Data You Provide. We mostly receive PII because you have provided it to us. For instance, when you contact us by phone or online, enter a competition or an event, sign up for training, complete a survey, purchase a product, or a certain service, attend an event we host, register and/or set up an account/profile, you may be provided with, or required to pick, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, or further details, such as your name, telephone number(s), email and/or home or business address. Other Data including your age, gender, photo, video, or even an avatar, as well as some of your preferences may also be requested. In addition, we may acquire your Data when you contact us by post/mail, or through your interaction with our social media pages or through messaging (e.g., email, SMS, MMS, Messenger, Viber, Whats App, Facebook, Twitter, Instagram, our blogs, or similar technologies) or when you sign up for our newsletters or alerts or communicate with us via email or other channels, such as our Contact Us form (in our website/blog) or by filling in a google form, etc. We also may acquire information that you provide about other people, for example, when you make a reference to a friend or purchase one of our Products/ Services as a gift. In all such cases the data provided come directly from you.
Data Automatically Collected and Log Files. The Site/Service may also automatically collect Data about you, your online behaviour and your Device and we may use log files to record data about each users’ visit to our Site.The Data collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP (Internet Protocol) address connected to your computer (or the proxy server you use to access the World Wide Web), pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data, as well as your mobile device operating system (if you are accessing the Site using a mobile device), or the name of your ISP (Internet Service Provider) or your mobile carrier. We may use this information to analyze overall trends to help improve the Site. We do not share log data with third-parties unless required by law to do so. The Service may collect your Data even if the Site is not open on your Device or you’re not logged in.
Data Acquired Elsewhere. We may also acquire your PII or other Data offline or otherwise outside of the Site/Service. For example, we may purchase or otherwise acquire such Data from third party data suppliers. We reserve the right to merge or commingle those other Data with your PII and Data collected on or through the Site/Service.
Social Network Integration. If you wish to access, visit and/or use any third-party social networking service(s) that may be integrated with the Site/Service, we may receive your Data that has been made available to those services, including information about your contacts on those services. For example, some social networking services allow you to push Content from our Site/Service to your contacts or to pull information about your contacts so you can connect with them on or through our Site/Service. Some social networking services also will facilitate your registration for our Site/Service or enhance or personalize your experience on our Site/Service. Your decision to use a social networking service in connection with our Site/Service is voluntary. However, you should make sure you are comfortable with your Data the third-party social networking services may make available to us by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We reserve the right to use, transfer, assign, sell, share, and provide access to all of your Data that we receive through third-party social networking services in the same ways as all of your Data we receive through our Site/Service (as described in Section IV below).
Be Careful Publicly Posting PII. Please be aware that Content and PII that you disclose in publicly accessible portions of the Site/Service may be available to other users, and may also be made available outside the Site/Service by third parties, therefore you should be mindful of all PII, especially sensitive PII, that you may wish to post.
Processing Your Requests for Services/Products. We use your Data to process your request for Content and/or other Service(s)/Product(s). For example, if you subscribe to any of our Services/Products, we may use your email address to send you invitations to events we will be hosting, to answer questions you submit to us (see FAQ), a confirmation note for the said Service and/or your postal address to send you the Product. Similarly, if you enter a competition/contest, we will use your PII to notify you if you are a winner. If you enter a competition/contest or submit Content to us (e.g., post, “letter to our editors” or online review or comment), we may also publish your name, screen name, home town and other PII you have provided to us. Other reasons for using your data is for us to send you our news and updates (newsletters, etc.), administer our business processes, as well as comply with our legal and contractual obligations.
Administering the Site/Service. We also use your Data for any lawful business purpose in connection with administering the Site/Service, including – without limitation – for customer service, to help diagnose problems with servers, to improve Services/Products that we offer by customising them to your needs, to gather broad demographic details, to analyse trends, to seek compatible advertisers/sponsors/clients/customers, etc., and to track users’ movements around the Site/Service and elsewhere on the web or across apps and/or devices. Your geographic location Data may specifically be used to show you Content (including advertising and sponsored messaging) based on said geographic location.
Access by Third Party Providers. We may also allow access to your Data by Third Party Providers that provide us with services, such as technical maintenance, market research, community and fora management, auction services, e-commerce, personal/job search and other advertising functionality, but only for the purpose of and to the extent necessary to provide those services. Should you choose to purchase or subscribe to any Service(s)/Product(s), we may forward your Data to Third Party Providers for services such as credit/debit card or other payment processing, order fulfilment, credit pre-authorization, and address verification. There are also times when you provide Data to us in areas of the Site/Service that may be managed or participated in by one or more Third Party Providers. In such cases, the Data may be used by us and by such Third Party Provider(s), each pursuant to its own policies. While we may seek to require Third Party Providers to follow appropriate privacy policies and will not authorize them to use your Data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.
Marketing Communications. We may also use your Data to communicate with you about new features, events, Services or Products offered by us, Third Party Providers, our advertisers, and other companies and individuals with which we have a collaboration of any sort.
Transfer or Sale of Our Business. As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Data may be among the transferred assets.
Combining Your Anonymous Data with PII. We reserve the right to merge or commingle anonymous, non-personally identifiable Data about you, your offline and online behaviour, and/or your Device (including its geographic location), with your PII for any lawful business purpose.
Credit/Debit Card and Payment Account Data. We will not sell or rent your credit/debit card number or payment account Data. We may only transfer such Data to Third Party Providers who need access to fulfil a transaction that you have consented to.
Sharing Your Data for Marketing. Unless otherwise specified on the Site/Service, we may sell or share your Data among our parent, subsidiaries, and affiliates and with other third parties who we think may offer or enable you to become aware of Services/Products that may be of interest to you.
How to Opt-Out of Marketing Messages from Us. If you do not wish to receive future marketing or other commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. But note that you may continue to receive certain communications from us that are necessary for the Site/Service, such as renewal notifications, invoices, technical notices, updates, security alerts, support, and administrative service bulletins.
Cookies/Local Device Storage. The Site/Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, or in our emails/communications such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third Party Providers may use Local Device Storage in connection with the Site/Service for any lawful business purpose, including – without limitation – to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control the display of advertisements, to track the movements of individual users through the Site/Service and elsewhere on the web or across apps, devices, social media, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalisation of information, and to generally optimally administer the Site/Service.
You May Disable Local Device Storage. If you do not want Local Device Storage, your Device or browser may include an option that allows you not to accept it. However, if you disable Local Device Storage, some parts of the Site/Service may not function properly.
Tracking Technologies. In addition to Local Device Storage, we may use web beacons, web bugs, internet or pixel tags, gifs, digital fingerprinting (“Machine Identification”) and similar technologies (collectively, together with Local Device Storage, and/or the “Tracking Technologies”) on the Site/Service and in our communications with you, such as within email and text messages and push notifications. We use Tracking Technologies to determine which of our messages have been opened by recipients, and for all or some of the same lawful business purposes described above for use of Local Device Storage.
Do Not Track (DNT). Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements adapted to their interests. As a result, like many websites and online services, we do not alter our practices when the Site/Service receives a DNT signal from a visitor’s browser. You may opt out of the use of your Data for online behavioural advertising by third parties at any time. To find out more about DNT, please visit http://allaboutdnt.com.
Opt-Out of OBA. If you do not want OBA, you may be able to opt-out by sending an email to [email protected] Please note that the option to opt-out applies only to tracking by Third Party Providers across this Site and other sites, applications, destinations and services, and not tracking among pages within the Site/Service itself. Residents of the European Economic Area (EEA) and Switzerland have additional options as described below in Section XII(B) to exercise choices with respect to OBA.
No Liability for Breach. Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the Data that you send to us or the security of servers, networks or databases, and by using the Site/Service you agree to assume all risk in connection with your Data. We are not responsible for any loss of such Data or the consequences thereof.
Breach Notification. In the event that we believe the security of your Data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by email, or otherwise.
For communications on other matters, please contact us through the means described on the Site/Service, if available (for example, in the “Contact Us” section)