Privacy Policy

Before using this website, you should carefully read this privacy policy document. By using this website, you agree to this Privacy Policy; otherwise you must immediately leave this website.

Company name, which is the owner of the Brand name brand, its other affiliates and subsidiaries (hereinafter referred to as Brand name, the "Website", "we", "our" or "us"), owns, operates or provides access to multiple interactive websites, mobile and connected apps and other interactive online features and services, including, among others, emails, newsletters, chats, forums, communities, sweepstakes and contests (collectively, the "Services"). This Privacy Policy applies to all information collected about you by Brand name through and in connection with the Services, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your data may be used, when your data may be disclosed, how you can control the use and disclosure of your information and how your information is protected.

Unless otherwise stated in this Privacy Policy, Brand name is the data controller (as that term is used in the EU General Data Protection Regulation "GDPR"), which means we decide how and why the information you provide to us is processed. This Policy may be changed or updated to reflect changes in our practices regarding the Processing of your information or changes in applicable law.

This Privacy Policy covers information collected through this website and all its subdomains.

We may Process: your personal data (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; your employer information (where applicable); information about your interactions with our content or ads; and any views or opinions you provide to us.

We may also Process information about your use of our Services (e.g., the type of device used, internet service provider, etc.), including your interactions with content and ads in the Services.

"Personal data" means information that relates to an individual or by which that person can be identified directly or indirectly.

"Processing", "Process" or "Processed" means anything done to any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, review, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We may process the following categories of Personal Data about you:

Personal data: your name; username or login details; password; areas or topics of interest; and a photograph (if you or another user posts a photo on the Service).

Demographic information: gender; age/date of birth; nationality; title; position, company information, education, work experience and other professional information; and language preferences.

Contact details: postal address; telephone and/or mobile phone number; email address; and your public social media handles or profiles.

Consent records: records of any consents you may have given, including date and time, manner of consent and any related information (e.g., subject of the consent).

Location information: location data that describes the precise geographic location of your device ("Precise Location Data").

Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or account holder name; payment amount; and payment due date.

Employer data: if you contact us as an employee, your employer’s contact information (including name, address, telephone number and email) to the extent relevant.

Views and opinions: any views and opinions that a user or other users choose to submit to us or publish about us publicly on social media platforms or in the Services, including forums.

We also collect other types of information from you or other sources that in this Policy we refer to as "Other Information", which may include, among other things:

Information about use of the Services, such as usage data and statistical information that may be aggregated.

Browsing history, including websites or other services you visited before and after interacting with the Services.

Searches and interactions with e-commerce capabilities, such as merchants and offers contained in the Services.

Imprecise information about the approximate physical location (for example at city or postal code level) of the user's computer or device, derived from the IP address of such computer or device ("GeoIP Data").

Device identification ("ID"), which is a distinctive number associated with a smartphone or similar handheld device but different from the hardware serial number.

An advertising identifier, which is a unique, user-resettable identifier for advertising purposes associated with the device (e.g., iOS

uses the advertising identifier (or "IDFA"), and Android uses the Google advertising identifier).

Internet Protocol ("IP") address, which is a unique string of numbers automatically assigned to your device each time you connect to the Internet.

Internet connection measures, such as internet service provider ("ISP"), mobile carrier, Wi‑Fi connection, service set identifier ("SSID"), international mobile subscriber identity ("IMSI") and international mobile equipment identity ("IMEI").

Information collected via cookies, eTags, JavaScript, pixel tags, device identifier tracking, anonymous identifiers and other technologies, including information collected by such methods and technologies about (i) your visits to the Services and interactions and engagement with them, content and ads on third‑party websites, apps, platforms and other media channels ("Channels") and (ii) your interactions with emails, including content and ads contained therein (collectively "Online Data").

Device type, settings and software used

Log files, which may include IP addresses, browser type, referring/exit pages, ISP, operating system, date/time stamps and/or clickstream data, including any clicks on personalized links.

Web beacons, which are electronic files that allow a website to count users who have visited that page or accessed certain files.

Pixel tags, also known as transparent GIFs, web beacons, beacon tags or network bugs, which are a method of conveying information from a user's computer to a third‑party website.

Shared local objects such as Flash cookies and local storage, such as HTML5.

Mobile analytics to understand functionality of our mobile apps and software on your phone.

In certain circumstances and depending on applicable law some of this Other Information may constitute personal data. Personal data together with other information are hereinafter referred to as "User Information".

Sensitive personal data

We do not seek to collect or otherwise process your sensitive personal data. If we need to process your sensitive personal data for a legitimate purpose, we will do so in accordance with applicable law. The Services are not intended for use by children.

We do not collect or otherwise process Personal Data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or convictions, or any other information that may be considered sensitive under the GDPR (collectively "Sensitive Personal Data") in the ordinary course of our business. In the event it becomes necessary to Process Sensitive Personal Data under the GDPR, we will rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data if the Processing is required or permitted by applicable law; crime detection and prevention: we may Process your Sensitive Personal Data where Processing is necessary for the detection or prevention of crime (including fraud prevention); establishment, exercise or defense of legal claims: We may Process your Sensitive Personal Data where Processing is necessary for the establishment, exercise or defense of legal claims; or consent: We may Process your Sensitive Personal Data if, in accordance with applicable law, we have obtained your prior explicit consent before Processing your Sensitive Personal Data.

Children. The Services are not intended for children, especially those under 13 years of age. Persons under 13 should not provide any personal data or use our public discussion areas, forums or chats. Minors under 18 may not make purchases through the Services or obtain coupons or codes from the Services to purchase goods or services on third‑party websites. If despite these prohibitions your children disclose information about themselves in our public discussion areas, there may be consequences not intended for children (for example, they may receive unwanted messages from other parties). If we learn that we have collected personal data from a person under 13, we will promptly delete that information.

How we collect or create information

We may collect or obtain User Information: directly from you (e.g., when you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your personal data public (e.g., if you publish a public post about us on social media); when you download, install or use our Services; when you visit our Services; during registration to use any part of the Services; or when you interact with third‑party content or ads in the Services. We may also receive User Information from third parties (e.g., social networks). We may also create User Information, such as

as records of your interactions with us. Brand name is not responsible for Personal Data that you voluntarily provide in public areas of the Services. This Policy does not cover third‑party practices that may share information about you with Brand name.

Collecting user information: We may collect user information from the following sources:

Information you provide: We may obtain your personal data when you provide it to us in the course of using our Services (e.g., when you register to receive emails, newsletters, bulletins, webinars or white papers; register for membership on the site or create a profile or account in any part of the Services; participate in sweepstakes, contests, promotions or prize draws; receive promotional information by SMS text message; participate in surveys; submit search queries via the Services; contact us by email, telephone or otherwise; purchase a subscription, software license or product; or when you provide us with your business card, etc.).

Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you (e.g., if you purchase a service from us).

Information you make public: we may collect or obtain personal data that you expressly choose to make public, including via social media (e.g., via our chats, forums or communities in the Services).

Service data: We may collect or obtain your personal data when you visit, download, use or register to use any part of our Service.

GeoIP and/or Precise Location Data (if permitted by your mobile device settings); and (c) other information including, among other things, IP address, internet service provider, institution or organization hosting the tested network and network, hardware and device identifiers such as the user's SSID or IMEI number (if the test is carried out on a smartphone). Brand name may collect your precise location data

Content and advertising information: If you choose to interact with third‑party content or ads in the Services or Channels, we may receive User Information from the relevant third party.

Third‑party information: We may collect or obtain your personal data from third parties that provide it to us. This may include offline channels such as telephone or direct mail; from customers, vendors, suppliers, third parties, commercially or publicly available sources (e.g., data brokers, data aggregators, public databases, etc.); external network operators; referral sources; social networking sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third‑party connection or login (e.g., Facebook Connect, Twitter or Google+) to access the Services, create membership or a profile in any part of the Services, access our content or share our content with another person, platform or service, we may also receive your username or email address for those third‑party services or other information available about you or collected from you in those services.

Please note that Brand name is not responsible for information you voluntarily provide about yourself in discussions in any public areas of the Services, such as comment sections, forums, blogs, wikis, chats, private messages, discussion boards or other publicly accessible interaction, or information you choose to make public in any of your user profiles or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Data in this way. You can change your publicly available information at any time on your profile page. To request removal of your personal data from those areas, contact us via our DSAR portal. In some cases we may not be able to remove your personal data. If so, we will inform you that we are unable to do so and why.

This Privacy Policy does not cover third‑party practices, including those that may disclose information to Brand name.

Creating user information. We may also create User Information, such as records of interactions with us and purchase history details, for internal administrative and analytical purposes. We may also combine data you provided with data obtained from third parties, such as social networks and other data‑gathering entities.

Purposes for which we may process your data

We may process User Information for the following purposes: to provide you with the Services; to communicate with you; to deliver ads to you in the Services and Channels; to analyze audience engagement; to observe user engagement and purchase‑related activity in the Service and Channels; to offer lead generation services between businesses; to market our services and offers to current and prospective customers; to manage our IT systems; to manage finances; to conduct

surveys; to ensure the security of our systems; to conduct investigations as necessary; to comply with applicable law; and to improve our Services.

The purposes for which we may Process User Information, in accordance with applicable law, include:

Providing user services: providing user services from Brand name or its partners, including (i) offering contests as well as chats, forums and communities, (ii) publishing personal opinions together with other recommendations, (iii) displaying personal reviews of products or services, (iv) enabling search for other site members using information you may already know about that member, such as username or full name and identifying users who meet those criteria, (v) managing your account and (vi) customer service and relationship management.

Offering and improving the Services: operating and managing the Services for you; delivering personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements or creating new Services; and notifying you of changes to our Services.

Surveys: engaging with you to obtain feedback on our Services.

Communications: communicating with you by any means (including email, telephone, text messages, social media, mail or in person) regarding messages and other information you may be interested in, provided such communication is delivered in compliance with applicable law; maintaining and updating contact details where appropriate; and obtaining your prior consent where required. We may conduct direct marketing as described in section 6 below.

Advertising: delivering interest‑based advertising based on your interactions with the Services and Channels, including using User Information to serve ads in the Services and Channels, and licensing segments of User Information to third parties. More information can be found in section 7 below.

Audience engagement: identifying and developing audience engagement, advertising and promotional strategies across platforms and channels, both within the Service and on Channels.

User engagement and purchases: tracking shopping traffic and activity in the Service and on Channels, including browsing history (where available); providing analytics and measuring return on advertising spend.

Commercial offers: using cookies to track browsing history and amounts spent on a particular external merchant’s site to offer coupons and other offers relevant to your purchases; offering coupons via SMS where a mobile phone number is provided.

Lead generation: generating business‑to‑business leads to provide clients with leads to improve targeted marketing campaigns and customer service through various strategies. This includes generating leads via phone calls and emails from marketing newsletters to direct you to content such as white papers and webinars offered by Brand name, after which your contact details will be shared with our client.

Customer‑targeted marketing: We may target ads to current and prospective customers and their employees who have expressed interest in working with or previously done business with Brand name to further generate and promote our business. Such activities include sending marketing emails or making telephone calls to encourage the purchase of advertising, acquisition of leads and other business services offered by Brand name.

IT administration: administration of Brand name's IT systems; network and device administration; network and device security; implementation of data and IT security policies; compliance audits with respect to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.

Security: electronic security measures (including monitoring of login logs and access data) to help mitigate risk and provide the ability to identify and remediate a security incident.

Financial management: general business and financial management purposes, including business, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements

Investigations: detecting, investigating and preventing policy breaches and crimes, in accordance with applicable law.

Legal proceedings: establishing, exercising and defending legal rights.

Compliance with law: Subject to applicable law, we reserve the right to disclose information concerning any user of the Services if we have reason to believe that such user is violating our Terms of Use or other published guidelines or is engaging in (or we have reason to believe is engaging in) any unlawful activity, and

to disclose information in response to court orders and government requests, other requests from government authorities, civil subpoenas, requests for disclosure and otherwise as required by law or regulatory obligations. We may also disclose user information if in good faith we believe such disclosure is in the interest of protecting the rights, property, safety or security of Brand name, any of our users or the public, or to respond to an emergency situation.

Direct marketing

We may process your User Information to contact you about services that may be of interest to you. You may opt out of subscriptions or opt out of SMS messages at any time free of charge.

We may process your User Information to contact you by email, telephone, direct mail, SMS or other communication methods to provide you with information about Services that may be of interest to you. We may send you information about Services, upcoming promotions and other information that may interest you using the contact details you provided to us and always in accordance with applicable law.

You may unsubscribe from our newsletters at any time by following the unsubscribe instructions contained in each email we send. We will not send you emails from a list you have unsubscribed from, but we may still contact you to the extent necessary for other Services you requested or to obtain additional emails to which you subscribed.

Cookies, similar technologies and online behavioral advertising

We may process your User Information by placing or reading cookies and similar technologies in the Services and Channels. For more information, please see our Cookie Policy. Some tracking technologies enable us to assign a unique identifier to a user and link information about use of the Services with other User Information, including User Information, to gain additional insights about the user so we can deliver relevant content and ads. We and our partners also use these technologies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods for measuring traffic and responses; track location and user movements within the Services; collect demographic information about our user base; and to better understand traffic to the Services, visitor behavior and responses to promotional campaigns.

Brand name and/or some third parties may collect User Information for Online Behavioral Advertising purposes to receive relevant interest‑based ads in the Services and on other websites, platforms and media channels. We use Online Data as well as other User Information to deliver online behavioral advertising to you. Online Data is aggregated with Other Information and data we collect and/or similar data collected by partners to create user groups and certain general interest categories or segments that we infer. We use this information to get a more accurate picture of audience interests and display ads we believe are more relevant to your interests.

Brand name and its partners may use cookies and other tracking technologies to analyze trends, administer the Services, track user movements in the Services and on third‑party websites, devices and apps, and to collect demographic information about our user base. You can control the use of cookies at the individual browser level, however if you choose to disable cookies, this may limit your ability to use some features or functions of the Services. To manage Flash cookies, click here. See our Cookie Policy for more information, including a more detailed explanation of what cookies are, the different types of cookies used in the Services and how to change or remove them.

Tracking technologies in the Services may be deployed by Brand name and/or by our service providers or partners. Some tracking technologies enable us to assign a unique identifier to a user and link information about use of the Services with other User Information, including User Information. We may match information collected from a user by different means or at different times and use such information together with offline and online information obtained from other sources (including third parties), including but not limited to demographic data and updated contact information, for example to obtain additional information about you so that we can deliver relevant content and ads.

When you receive emails or newsletters from us, we may use web beacons, customized links, clear GIFs or similar technologies to determine whether an email was opened and which links you clicked to provide more targeted email communication or other information and/or to aggregate that information with other data we collect for use in some or all of the purposes described in this Privacy Policy.

We and our partners (including, among others, e‑commerce partners, affiliate entities and analytics service providers) may also use technologies such as pixel tags, eTags, IP addresses, shared local objects, local storage, Flash and HTML5 cookies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods for measuring traffic and responses; track location and user movements within the Services; collect demographic information about our user base; and to better understand traffic to the Services, visitor behavior and responses to promotional campaigns. We may receive reports based on the use of these technologies by those third parties on an individual and aggregated basis. For example, we may combine information about your IP address with known company or User information and use related aggregated content preference information to assist our efforts to sell services to you or the corporation you represent. Different browsers may offer their own management tools for removing Local Storage. To manage shared Flash local objects, click here.

We may use mobile analytics software to collect data and better understand functionality of our mobile software, devices and apps on your phone and other devices. This software may record information such as frequency of app use, in‑app events, aggregate usage, performance data and the country from which the app was downloaded. We may link this information to User Information.

Brand name and/or some third parties may collect User Information for Online Behavioral Advertising ("OBA") purposes to receive relevant interest‑based ads in the Services and on other websites, platforms and media channels. OBA is also referred to as interest‑based advertising.

Brand name displays ads both in the Services and on Channels. We may use Online Data as well as other User Information to deliver OBA to you. For example, if you read an article on a particular topic in the Services, we may use a provider's cookie to later display an ad for a particular product or service related to the article you viewed. Such third‑party providers may combine information about pages you visit in the Services with information about pages you visit on other Channels and show you ads based on those combined data. These ads may appear when you visit another section of the Services or another Channel. Similarly, third‑party providers may show you ads when you visit the Services based on your interactions with the Services and other Channels.

Specific OBA service providers we use may change. For a list of some relevant providers, click here. For information on how to opt out of tracking methods for those entities and others, click here. For more information about OBA and opting out, see section 15 below. Online Data is aggregated with Other Information and data we collect as described in this Privacy Policy and/or similar data collected by partners to create user groups and certain general interest categories or segments we infer based on (a) demographic or interest data and GeoIP Data, (b) pages viewed and links you click while browsing emails or using the Services and our partners, and/or (c) search terms you enter while using certain search services. We use this information to get a more accurate picture of audience interests and display ads we believe are more relevant to your interests. We store page impressions, clicks and search terms used for ad personalization separately from your personal data.

What is the legal basis for processing personal data?

We may process your User Information where: you have given consent; Processing is necessary to enter into a contract between you and us; Processing is required by applicable law; Processing is necessary to protect the vital interests of any individual; or where we have a legitimate legal interest in processing.

In processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

Consent: We may Process your User Data if we have obtained your prior, explicit consent for the Processing (this legal basis is used only in relation to Processing that is entirely voluntary – it is not used for Processing that is in any way necessary or mandatory);

Contractual necessity: we may process your User Data if the processing is necessary in connection with any contract you may enter into with us; compliance with applicable law: We may

access your User Information where Processing is required by applicable law; vital interests: we may process your User Data where processing is necessary to protect the vital interests of any person; or legitimate interests: We may process your User Information where we have a legitimate interest in carrying out the Processing to manage, operate, improve or promote our business, and that legitimate interest is not overridden by your interests, fundamental rights or freedoms.

As described above, we have identified legitimate interest as the basis for processing in connection with Brand name's offerings and how we promote our business to our current and prospective customers.

What information do we disclose to third parties

We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties that process User Information on our behalf ("Processors"); any party where required in connection with legal proceedings; any party where necessary to conduct investigations, detect or prevent crime; any purchaser of our business; and any external providers of advertising, plugins or content used in the Services.

We may disclose your User Information to other entities within the Company Group for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

legal and regulatory authorities, upon request or to report any actual or suspected breach of applicable law or regulation; external professional advisors (such as accountants, auditors or lawyers), subject to binding contractual confidentiality obligations; external Processors (such as analytics providers, data centers, etc.), located anywhere in the world, subject to the requirements set out below in this section 9; any relevant party, law enforcement agency or court, to the extent necessary to establish, exercise or defend legal rights; any appropriate party to prevent crimes, to investigate them, detect or prosecute them or carry out criminal penalties, including protection from and prevention of threats to public safety; any appropriate third‑party purchasers in the event we sell or transfer all or a relevant part of our business or assets (including in connection with a reorganization, dissolution or liquidation); any relevant third‑party provider where our Services use third‑party ads, plugins or content. If you choose to interact with such ads, plugins or content, information about your actions in the Services and Channels to deliver targeted ads based on your interests may be shared with the relevant external provider. If you click, tap or otherwise interact with an ad, the advertiser may assume that you meet its targeting criteria; any sponsors of contests, competitions, sweepstakes and prize draws or white papers, webcasts or other downloads, registration data for such events is intended to be used by us as part of the User Information and may be shared with the sponsor and other parties, subject to this Policy and the sponsor's privacy policy. We may also share your data with external vendors involved in administering such events. For contests, competitions, sweepstakes and prize draws please carefully review the official rules or terms before submitting information; and third parties whose practices are not covered by this Privacy Policy (e.g., external suppliers of goods and services, marketing and advertising firms and agencies, content publishers and retailers).

For some of our Services we may share certain information, such as the names and postal addresses of our users, their phone number, email address — and in certain circumstances the name of their employer, company size and other industry data — on loan or other basis (e.g., sale) to external suppliers of goods and services, for example where such information is provided in connection with webcasts, technical papers or other sponsored downloads.

When you use a co‑branded service (a service operated by an Brand name partner) or register or otherwise provide information on a co‑branded site, you authorize us to transfer the collected information to that partner, which may include external service providers whose services are embedded in and/or appear in the Services;

In relation to surveys, where responses are publicly disclosed, users will be notified at time of completing the survey. Otherwise, we will only disclose aggregated information about survey respondents to other survey participants. Where surveys allow users to submit written comments and where Brand name notifies users of the possibility of such disclosure at the time of completing the survey, Brand name reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user will be disclosed.

Brand name and some of our advertisers may use external advertising service companies to serve OBA or otherwise and provide related services when a user interacts with the Services. These external advertising companies often use cookies and other technologies to measure ad effectiveness on websites, apps and emails and to create a record of interactions with our content that they use in conjunction with ads shown on other websites or in other apps, or to report site traffic, app usage, statistics, advertising data and/or other activity in the Services. We also engage external providers to help segment these data.

We may also sell or provide Online Data to certain third parties, such as advertisers, who will use that data to show ads they believe are relevant to your interests and who agree to keep that information confidential. Some of these third parties may combine Online Data with their own user data to create a more detailed picture.

We may engage external providers to assist in the collection, storage and segmentation of Online Data, and those providers are required to keep that information confidential. These external providers may collect User Information from our Services for their own purposes, including, among other things, monitoring online fraud.

We may also engage third parties to identify our users and deliver interest‑based content and ads to them. We may share User Information with our partners, such as name, postal address, email address or other identifier. Our partners may also: (i) collect information directly from your device such as IP address, device identifier, advertising identifier and information about your browser or operating system; (ii) combine User Information received from Brand name with information about you from other websites or services; and (iii) place or recognize a unique cookie in your browser.

If we engage an external Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) Process User Information only in accordance with our prior written instructions; and (ii) apply measures to protect the confidentiality and security of User Information; together with any additional requirements arising from applicable law.

The Services contain links to other sites or partners whose information practices may differ from ours. You should review the privacy policy of those third parties to learn how your privacy is protected.

International transfers of information

We may transfer your personal data to recipients in other countries. Brand name participates in the EU‑US Privacy Shield, the Swiss‑US Privacy Shield and the APEC Cross‑Border Privacy Rules System. If we transfer User Information from the European Economic Area ("EEA") to a recipient outside the EEA that is not in an adequate jurisdiction, we do so on the basis of standard contractual clauses.

Due to the international nature of our business, we may be required to transfer your User Information within the Brand name group of companies and to third parties as mentioned in section 9 above, in connection with the purposes set out in this Policy. For this reason we may transfer your User Information to other countries where different data protection laws and requirements may apply than those in the country in which you are located.

Brand name and its affiliated entities in the United States participate in and certify compliance with the EU‑US Privacy Shield and the Swiss‑US Privacy Shield frameworks. Brand name is committed to submitting all Personal Data received from Member States of the European Union (EU) and Switzerland, under the Privacy Shield principles, to the applicable principles of those frameworks. To learn more about the Privacy Shield, visit the U.S. Department of Commerce Privacy Shield list. Brand name is responsible for Personal Data it receives under the Privacy Shield and subsequent transfers to a third party acting as an agent on its behalf. Brand name adheres to the Privacy Shield principles with respect to all onward transfers of personal data from the EU and Switzerland, including the liability provisions for onward transfers. In relation to Personal Data received or transferred pursuant to the Privacy Shield, Brand name is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In some instances Brand name may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are an EU resident with a complaint, concern or question about Brand name's privacy practices please contact us via our DSAR portal. Under certain conditions, more fully described on the Privacy Shield website, individuals in Europe may invoke binding arbitration where other dispute resolution procedures have been exhausted.

If we transfer your personal data from the EEA to recipients outside the EEA that are not in a jurisdiction formally recognized by the European Commission as providing an adequate level of protection for personal data, we do so on the basis of standard contractual clauses. You may request a copy of the relevant standard contractual clauses via our DSAR Portal.

Please note that where any Personal Data is transmitted directly to a Company entity located outside the EEA we are not responsible for such transfer of Personal Data. Nevertheless, we will process your personal data from the time we receive the data in accordance with the terms of this Privacy Policy.

Brand name's privacy protection practices described in this Privacy Policy are aligned with the Asia‑Pacific Economic Cooperation ("APEC") Cross‑Border Privacy Rules System. To learn more about this program, click here.

Please note that we may use data collected by an external operator/licensee of localized versions or editions of the Services.

Data protection

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any personal data you send us is transmitted securely.

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In some cases we may employ Secure Sockets Layer encryption and/or transmit certain User Information in a human‑unreadable format to provide protection. However, we cannot guarantee that breaches will not occur and are not liable for any security breach or the actions of third parties.

Because the Internet is an open system, transmission of information over the Internet is not completely secure. While we will take reasonable measures to protect your data, we cannot guarantee the security of data transmitted to us via the Internet. Any such transmission is at your own risk and you are responsible for ensuring that any personal data you send to us is transmitted in a secure manner.

Data accuracy

We take all reasonable steps to ensure that your User Information is accurate and up to date and is deleted or corrected if we become aware of inaccuracies.

We take all reasonable steps to ensure that your User Information that we process is accurate and, where necessary, up to date, and that any User Information we process that you notify us is inaccurate (taking into account the purposes for which it is processed) is erased or rectified.

Data minimization

We take all reasonable steps to limit the amount of User Information we process to the minimum necessary.

We take all reasonable steps to ensure that your User Information that we process is limited to User Data that is reasonably necessary in relation to the purposes set out in this Policy or required to provide the Services or access to the Services.

Data retention

We take all reasonable steps to ensure that your User Information is retained only as long as necessary. Online Data related to OBA is retained by Brand name for no longer than 180 days, after which it expires, subject to meeting certain conditions.

We take all reasonable steps to ensure that User Information is processed only for the minimum period necessary for the purposes set out in this Policy. The criteria used to determine how long we will retain your User Information are as follows: we will retain copies of your User Information in identifiable form only for as long as is necessary in relation to the purposes set out in this Policy, unless applicable law requires a longer retention period. Where there is no specific legal requirement to retain information, we plan to keep it no longer than necessary to satisfy a legitimate business need.

Unless otherwise stated in this Privacy Policy, Online Data related to OBA is retained by Brand name for no more than 180 days, after which it expires. The 180‑day period may restart if the same user subsequently visits, views or interacts with the ad, email, Services or Channel.

What can I do to control my data?

You can take direct steps to change your newsletter and online behavioral advertising preferences as described in this section.

If you are an EU resident you may have various rights, including: the right not to transfer Personal Data to us; the right to access your personal data; the right to request rectification of inaccuracies; the right to request deletion or restriction of processing of your personal data; the right to object to Processing of your Personal Data; the right to have your personal data transferred to another controller; the right to withdraw consent; and the right to lodge a complaint with a supervisory authority. We may request proof of identity or verify your identity before we can give effect to these rights.

You can take direct steps to change your preferences as follows:

Access to your personal data. On request Brand name will inform you whether we hold any of your personal data. You can access, correct or request deletion of your personal data by logging into your account or contacting us by email.

Your newsletter and email subscriptions. You may unsubscribe from receiving a newsletter or other email list at any time by following the unsubscribe instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some Services, communications related to membership services are an integral part of such Services you subscribe to and you may continue to receive emails as part of that specific portion of the Services unless you cancel your account, even if you unsubscribe from newsletters or the email list. If you have provided us more than one email address, we may still contact you unless you request the cancellation of the subscription for each email address provided.

Push notifications. From time to time we send you push notifications to inform you about events or promotions we run. If you no longer wish to receive such communications you can disable them at the device level. To ensure you receive relevant notifications we will need to collect certain information about your device, such as the operating system and user‑identifying data.

Residents of the European Union and Switzerland should visit the European DAA by clicking here.

Residents of the United States and residents of all other countries or territories not listed above may click here to go to the DAA site to learn more about cookie use, opt‑out options and more.

Cookies and pixel tags. You can stop or limit cookies and pixel tags on your computer or remove cookies from your browser by adjusting your web browser preferences. However, if you "disable", delete or turn off cookies or pixel tags, although you may still use the Services, you may not be able to use all features, functions or services available in the Services.

Location‑based Services. You may opt out of Brand name collecting your precise location data at any time by editing the relevant setting on your mobile device (which is typically found in your device Settings).

Speed Test app and Web Speed feature. To disable the Speed Test app background scanning feature, go to the coverage maps settings or feature in the Speed Test app and toggle the background scanning feature to "Off". Please note that if your smartphone or mobile device settings do not allow transmission of Precise Location Data, some features may be unavailable or their functionality may be limited. You can opt out of the Speed Test Web Speed feature at any time by adjusting settings in your web browser.

Residents of California. Under the California Online Privacy Protection Act we may collect Personal Data about your online activity while using the Services. While we provide our users with many opt‑out choices for sharing personal data, we do not respond to browser "do not track" signals. The California "Shine the Light" law, Civil Code section 1798.83, permits our users who are California residents to request and obtain certain information regarding any Personal Data disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish us to refrain from collecting your personal data, please submit your request in writing using the contact details in section 17 below.

Residents of the EU. The GDPR provides certain rights to EU residents. You may refuse to provide us with certain information, in which case we may not be able to provide certain features and functionalities of the Services. These rights include, as applicable, the right to object to or request restriction of processing of your data and to request access to, rectification, deletion and portability of your information. Where we process your data on the basis of your consent, you have the right to withdraw that consent (provided that such withdrawal does not affect the lawfulness of Processing carried out prior to the date on which we receive notice of such withdrawal, and does not prevent Processing of Personal Data based on other available legal bases). Requests should be made by contacting us via the DSAR Portal. If you are an EU resident and have an unresolved privacy issue that we have not addressed to your satisfaction after contacting us, you have the right to contact the relevant EU supervisory authority and file a complaint.

Terms of use

Brand name Terms of Use govern use of the Services.

For more information about use of the Services, visit Brand name Terms of Use. The Brand name Terms of Use are incorporated by reference into this Privacy Policy.

Contact details

You can contact us at the addresses below or by email

email@domain.com

Street 100 00000 City

tel. +34 123123123

If you have any comments, questions or concerns about any information contained in this Policy or any other matters relating to our processing of user information on our behalf or on our behalf, please contact:

Company name

Street 100 00000 City

tel. +34 123123123

email@domain.com

Our Data Protection Officer can be contacted at email@domain.com

If you have unresolved concerns about your privacy or our use of data that we have not addressed to your satisfaction, please contact the European Commission platform for online dispute resolution (ODR) at http://ec.europa.eu/consumers/odr/.

How this Privacy Policy may change

We may change this Privacy Policy, and any changes will be effective upon posting.