This Website collects some Personal Data from its Users.
Owner and Data Controller
Mary McGlynn, David Azevedo
200B Twin Dolphin Drive
Redwood City, CA 94065
(650) 631-8459 or (800) 828-1909
Contact email: email@example.com
External Web pages and links
We refer to external websites in various places, which can usually be recognized as links. We assume no responsibility for the contents of the linked websites. Likewise, we can provide no information regarding data protection and data security of the links and external websites.
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies and Usage Data.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
Details about collection and processing of personal data
The European Data Protection Ordinance and the Federal Data Protection Act attach great importance to privacy and the protection of personal data. We implement these regulations in our behavior, our processes and technical in line with the technology currently available. In the following paragraph you will receive detailed information about your rights as well as the collection, storage, processing and deletion of your data.
The legal basis for the collection and processing (article 6 EU GDPR lawfulness of processing) is as follows:
- Consent (Art. 6 para. 1 lit. a), i.e. you have consented to the processing of your data by us (e.g. for receiving the newsletter)
- Necessary to the performance of the contract (art. 6 para) 1 lit. b), i.e. we collect the data necessary to execute a contract or order (e.g. address and payment details)
- For the fulfilment of a legal obligation required, which the officer is subject to, (art. 6 para) 1 lit. c), i.e. we are legally obliged to store the data (e.g. for tax authority controls)
In the following we describe the individual situations in which we process your personal data.
a) Access to general information on our website
You can normally access all our website pages without entering any personal data. For security reasons and for internal statistical purposes, we collect the following usage data (server log files) for each visit:
- Your (shortened) IP address
- The amount of data transferred
- Date and time of access
- Which pages you have visited with us
- The page from which you accessed our website
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer, time of the server request
The data is not personalized.
b) Concrete inquiries and orders
For specific inquiries or orders, we are legally obliged to collect a minimum amount of personal information in addition to the details mentioned under a). In these cases, we process the personal data provided by you exclusively for contract processing and processing your inquiries.
Personal data includes details such as name, address or email address. The prerequisite is that you provide us with this information voluntarily and explicitly. By doing so, you make it clear that you agree to its use and processing. In accordance with the European data protection regulation, we collect only the absolutely minimum amount of data that are necessary for the execution of the order or request. These data are deleted after the legal retention periods have expired.
c) email contact
If you provide us your email address (either via the contact form or by email, we will gladly use it to communicate with you.
Please note that in most cases emails are transmitted unencrypted and therefore no confidentiality of the transmitted information is guaranteed. The content of emails can be viewed by third parties, an email message is similar to a postcard in terms of security. We therefore recommend that you send us confidential information exclusively as a letter by traditional mail.
You can revoke your consent to email communication with us at any time. In this case, please send us a short message to the respective postal or email address given.
If you would like to subscribe to our newsletter, we need your email address as well as your first and last name. The registration process is as follows: after registering for the newsletter, you will receive an automatically generated confirmation e-mail to subscribe to the newsletter. The confirmation link contained therein must be clicked on by you, by doing so you agree to receive the newsletter. Then you will receive regularly updated and interesting information from us. When you open the newsletter email, the following data will be sent to us:
- Name/email address of the subscriber who has opened the newsletter
- Clicked on links contained in the newsletter, incl. number of clicks
- Time of registration to the newsletter
- Time of un-subscription from the newsletter, if applicable
- Responses or error messages (email account not accessible or full)
- Geographical information
We evaluate this data statistically in order to be able to offer our customers and prospective customers an optimal service. By subscribing to the newsletter, you agree to the use of your data. We do not use your data for any other purpose and of course do not share it with third parties.
You can at any time unsubscribe from the newsletter and revoke your consent. Please click on the corresponding link in the newsletter.
e) Credit card purchases
We ask you for the following personal information for the purposes of processing payment for purchases made via our website:
- your name
- your billing address
- your email address
- your phone number
- your credit card information
- your contact preferences
We work with a service provider to process your payment details. We do not store your payment details locally, just the invoices and required details for the execution of your order.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
- In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Duration of storage of personal data & Retention Time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
If you subscribe to our newsletter, we store the necessary data during the subscription period.
In general, we observe the principles mentioned in Art. 5 EU GDPR with regard to the processing of personal data:
- “Legality, processing in good faith, transparency”
- Data minimization
- Storage limit
- Integrity and confidentiality
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Interaction with external social networks and platforms, User database management and Platform services and hosting.
Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
If you want to exercise your right in these cases, we support your request free of charge. In this case, please contact us in writing with proof of identity (e.g. identity card or passport). We will be happy to inform you whether and if so which personal data we store about you and correct any errors. You have the right to withdraw your consent to use of data partially or fully for the future. If you wish, we will delete or block your corresponding data.
According to art. 12 para. 3 of the EU GDPR we will immediately, but in any case, within one month of receipt, execute the application. Please keep in mind that it can take longer in complex cases. We will inform you if we are unable to complete your application within 4 weeks.
In the event that you instruct us to delete or not to use your personal data, as a consequence we will be unable to provide a personalized service, as this is based on customer data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services.The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
This site uses SSL encryption for security reasons and to protect the transmission of confidential content. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon in your browser line is visible.
We store your data in our own data center and with certified cloud providers in the USA. Access to information is protected and only possible to authorized employees. We regularly review our security standards and update them according to technical progress, to keep the risk of misuse of data as low as possible. At the same time, we must point out that there is not one hundred percent security.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Latest update: September 25, 2019