PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE APP OR OUR SITE.
THE APP AND SITE ARE INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND THEY ARE NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.
RECHARGE is committed to protecting and respecting your privacy rights. This Privacy Policy, which applies whether you use our website www.recharge.city and the RECHARGE mobile application, or contact us by telephone or email, provides you with information about: What personal data we collect; How we use that personal data; Disclosures of your personal data to third parties; and The legal bases on which we rely on to process your personal data. For the purposes of this Privacy Policy, both the website and application shall be referred to as the “Platform”. You do not need to take any action as a result of this Privacy Policy, but you may have certain legal rights as described below. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. This Platform is not intended for children and we do not knowingly collect or solicit data relating to children.
RECHARGE is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process.
IMPORTANT INFORMATION AND WHO WE ARE
Kamaletdos LLC (referred to in this Privacy Policy as “RECHARGE”, “we”, “us” and “our”) is the “data controller” of your personal data. In simple terms, this means that we: (i) “control” your personal data, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or are otherwise permitted by law.
How to contact us or make complaints
If you have any concerns or questions regarding our use of your personal data (including any requests to exercise your legal rights) or this Privacy Policy please contact love@recharge.city, Changes to this privacy policy and your personal data This Privacy Policy is regularly reviewed and was last updated on 23th November 2021. We may amend or update our Privacy Policy from time to time. It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.
2. THE PERSONAL DATA THAT WE COLLECT ABOUT YOU
The types of personal data we collect, use and store about you will depend on the product or service you have requested from us and/or the nature of your interaction with us. When using the Platform, we collect and process the following types of personal data: a) your name, phone number, email address and credit/debit card details; b) personal, device and business contact information (such as your email address, mobile number and IP address); c) login and account information (including mobile number and unique user ID); d) location data (including the location, date and time a power bank is rented and returned and places and preferences that you submit); e) payment or credit card information; f) technical information (including the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting); i) other personal data that you submit to us, such as information you provide to register for email alerts or correspond with us in relation to inquiries; and The Platform is not intended for children and we do not knowingly collect or solicit personal data from anyone under the age of 18. We do not collect any special category personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW WE OBTAIN YOUR PERSONAL DATA
Information you provide to us We collect information about you directly that you provide to us via the Platform in online forms and conversations and in other correspondence (including via email and telephone). Information we get from other sources We will automatically collect data from you accessing the services via the Platform (including if you register as a user of the Platform, subscribe to any service or upload or submit any material via the Platform). This information includes information relating to your device, as well as location information (if you have permitted us to collect such information). We use it to optimise our network, as well as keep you informed, such as with notifications to remind you to return a rental, or when your battery’s running low and you’re near aRECHARGE point. We are also working closely with and may receive information about you from third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies. We also collect personal data from publicly available sources. In connection with an employment inquiry, we collect data from third parties regarding your work authorisation status, education history, employment history and professional designations, and other information about your qualifications. We may combine personal data that you provide to us with information that we collect from, or about you, in some circumstances. This will include information collected in an online or offline context.
4. HOW WE USE YOUR PERSONAL DATA
We will use your personal data for the following purposes, and pursuant to the corresponding legal bases: 1. To enter into, and perform, contracts with you that you have requested, including sending you welcome and periodic emails that provide details on how to use our service and the mobile application and regarding the administration of your account (e.g., updating payment card details); building a profile of your preferences so that we can ensure our services are provided when you need them; processing payments for the services we provide; and processing payment of fees to use the power banks. a) Performance of a contract with you 2. To track your pickup and drop off locations and where the nearest power banks to you are. a) Performance of a contract with you b) Necessary for our legitimate interests (to track the power banks that we own). 3. To manage our relationship with you, including notifying you about changes to our terms or this privacy policy and asking you to leave a review or take a survey. a) Performance of a contract with you b) Necessary to comply with a legal obligation. c) Necessary for our legitimate interests (to study how customers use and rate our products and services, to develop them and our business). 4. To improve the Platform and products and services that we offer, including recognising when there is a higher demand for our services; tailoring our Platform to the needs of all users; recommending options that match any stated preferences; and notifying you about changes to our services. a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). 5. To enable us to manage customer service interactions with you. a) Necessary for our legitimate interests (to understand how our customers use our products and services and improve our business). 6. To keep a record of your relationship and purchase history with us. a) Necessary for our legitimate interests. 7. To verify your identity and to identify and prevent fraudulent transactions. a) Necessary to comply with a legal obligation. b) Necessary for our legitimate interests. Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. No automated decision making, including profiling, is used when processing your personal data. Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will receive marketing communications from us if you have requested information from us or purchased products or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have expressly consented to receiving that marketing. We will get your express opt-in consent before we share your personal data with any company outside RECHARGE for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at support@recharge.city Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience or other transactions (which we will continue to process in order to perform a contract with you or as a result of our regulatory or legal obligations).
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We will disclose your personal data with third parties if required to do so by law or regulation. We will also share your personal information with the parties set out below for the purposes set out in this Privacy Policy: External Third Parties as set out in the Glossary. Specific third parties such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
HOW DO WE USE AND SHARE YOUR INFORMATION?
How do we use the information described in this Policy?
To the extent permitted by applicable law, we may use the information described above in order to:
-- To facilitate and process your rentals;
-- Operate and improve our business, services, and the App and the Site;
-- Provide you with services, products, content, customer service, and functionality;
-- Honor our terms of use and contracts;
-- Manage our relationship with you;
-- Process and complete payments and other transactions;
-- Improve our products and services and develop new products and services;
-- Maintain our databases and back-ups, including records of our communications with you;
-- Ensure the privacy and security of our App, Site and services;
-- Detect fraud and prevent loss;
-- Support and improve the App and the Site, including evaluations of functionality and features;
-- Improve our customer service;
-- Communicate with you and respond to your feedback, requests, questions, or inquiries;
-- Promote our products and services;
-- Contact you about other products and services;
-- Improve our marketing efforts, including by providing more tailored advertising;
-- Administer a contest, promotion, or survey;
-- Administer rewards, referral, and promotional programs;
-- Assess the success of our marketing and advertising campaigns;
-- Analyze use of the App, the Site and our services and prepare aggregate traffic information;
-- Recognize your device and remember your preferences and interactions;
-- Provide you with a more personal and interactive experience on the App and the Site;
-- Determine and track user interests, trends, needs, and preferences;
-- Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers;
-- Obtain and maintain insurance coverage, manage risks, and obtain professional advice;
-- Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your information was provided to us;
-- Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law;
-- Comply with federal, state, or local laws;
-- Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, order, or summons by federal, state, or local authorities;
-- Cooperate with law enforcement agencies;
-- Exercise or defend legal rights or claims; and
-- Create, use, retain, or disclose de-identified or aggregated data.
How do we disclose or share the information described in this Policy?
Where permitted by applicable law, we may share the information described above in the following contexts:
6. YOUR LEGAL RIGHTS
Access: You have the right to ask for a copy of
the personal data that RECHARGE holds about
you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive, to help us cover the costs of locating
the information you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month. Correction: If there are any inaccuracies
in the information we hold about you, please contact us and we will correct them. Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you
may request that we delete it. Please note that
this may not always be possible due to legal obligations. Restrictions on use: You may
request that we stop processing your personal
data (other than storing it), if: (i) you contest
the accuracy of it
(unless the accuracy is verified);
(ii) you believe the processing is against the law;
(iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your data
to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
Object: You have the right to object
to processing of your personal data 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 data 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 the transfer: If you wish to transfer
your personal data to another organisation (and certain conditions are satisfied), you may
ask us to do so, and we will send it directly if we have the technical means. Please 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. Withdrawal of consent: If you previously gave us your
consent to allow us to process your personal
data for a particular purpose, but you no longer wish to consent to us doing so, you can contact
us to let us know that you withdraw that
consent. 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.
7. COOKIES
Our website uses cookies. A cookie is a small
file of letters and numbers stored by computer after being sent to your computer when you
visit a website. Whenever you visit the same website again, the information stored in the
cookie can be retrieved to notify the website
of your previous activity. We use cookies to facilitate website navigation,
maintain quality of online service, provide additional security, sending emails, allow the customisation
of your access to the website and remember
you when you return to the website. A cookie cannot give us access to your computer or to information beyond what you provide us and
we don’t store personally identifiable
information such as your name or address in
cookies we create, but we do use encrypted information gathered from them to help
improve your experience of the website. If you don’t wish to enable cookies, you’ll still
be able to browse the website and use it for research purposes. You can choose to have your computer warn you each time a cookie is
being sent, or you can choose to turn
off/on certain cookies. You do this through your web browser settings. Each browser is different,
so look at your browser Help menu to learn the correct way to modify your cookie settings.
Cookies and Similar Technologies
First and Third-Party Cookies
A “cookie” is a small file created by a web
server that can be stored on your device (if you allow)for use either during a particular
browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily
stored on your hard drive and only last until
they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain
stored on your hard drive until they expire
or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and
navigation to, from, and on a website.
First-party cookies are set by the website
you’re visiting, and they can only be read
by that site. Third-party cookies are set
by a party other than that website.
Other Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet
tags, web beacons (clear gifs, pixel tags, and
single-pixel gifs), and navigational data
collection (log files, server logs, etc.) that can
be used to collect data as users navigate
through and interact with a website:
-- Web beacons: These are tiny graphics
(sometimes called “clear GIFs” or “web pixels”)
with unique identifiers that are used to
understand browsing activity. In contrast to
cookies, which are stored on a user’s device,
web beacons are rendered invisible on web
pages when you open a page.
-- Social Widgets: These are buttons or icons provided by third-party social media platforms
that allow you to interact with social media services when you view a webpage or mobile
app screen. These social widgets may collect browsing data, which may be received by the
third party that provided the widget and are controlled by third parties.
-- UTM Codes: These are strings that can
appear in a URL (the “Uniform Resource
Locator,” which is typically the http or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across
different websites and other online services
may be associated with your personal
information and used to provide you with
targeted content. We do not control these
third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible
party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies,
you may choose to not allow certain cookies
via a cookies consent banner or you may set
your browser to refuse all or some types of
cookies or to alert you when cookies are being
sent by website tracking technologies and advertising.
Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the
cookie settings on the Site may not fully delete
all of the cookies that have already been
created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site.
8. DATA RETENTION
We will only retain your personal data for
as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in
the event of a complaint or if we reasonably believe there is a prospect of litigation in
respect to our relationship with you.
To determine the appropriate retention
period for personal data, we consider the
amount, nature and sensitivity of the personal
data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention
periods for different aspects of your personal
data are available in our retention policy
which you can request from us by contacting us.
We retain and use your information for as
long as is necessary to fulfill the purposes for which it was collected, to comply with our
business requirements and legal obligations, to resolve disputes, to protect our assets, to
provide our services, and to enforce our agreements.
We may delete your information if we believe
it is incomplete, inaccurate, or that our
continued storage of it is contrary to our
objectives or legal obligations. When we delete data, it will be removed from our active servers
and databases, but it may remain in our archives when it is not practical or possible to delete it.
To the extent permitted by law, we may retain
and use anonymous, de-identified, or
aggregated information for performance
reporting, benchmarking, and analytic purposes
and for product and service improvement.
HOW DO WE PROTECT YOUR
INFORMATION?
We have put security measures in place to
protect the personal information that you share with us from being accidentally lost, used,
altered, disclosed, or accessed in an
unauthorized manner. From time to time, we
review our security procedures to consider appropriate new technologies and methods.
While our security measures seek to protect
the personal information in our possession, no security system is perfect, and no data
transmission is 100% secure. As a result, while
we strive to protect your information, we
cannot guarantee or warrant the security
of any information transmitted to or from
the App or the Site. Your use of the App and
the Site is at your own risk. We cannot
guarantee that your data will remain secure in
all circumstances.
The safety and security of your personal information also depends on you. Where you
use a password for access to the App, you are responsible for keeping the password
confidential. Do not share your password with anyone. You should also take care with how you handle and disclose your personal information
and should avoid sending personal information through unsecure email.
If a data breach compromises your personal information, we will notify you and any
applicable regulator when we are required to
do so by applicable law.
YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION
Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.
Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at ____________________________ and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Please note that Registered Users on the App cannot opt out of receiving transactional e-mails related to their account.
Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information.
If you have created a user account for the App, you may access, review, and make changes to your User Registration or Payment Information by following the instructions in the App. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and
about children on the Internet. Our App, Site
and services are not directed to children aged
13 or younger, nor is information knowingly collected from children under the age of 13. No
one under the age of 13 may access, browse, or
use the App or the Site or provide any
information to or on the App or the Site. If
you are under 13, please do not use or provide any information on the App or the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent,
we will take steps to stop collecting that information and delete it. If you believe we
might have any information from or about a
child under the age
of 13, please contact us via the “Contact Us”
details provided at the end of this Policy.
For more information about COPPA, please visit
the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
CONTACT US
For more information, or if you have any questions or concerns regarding this Policy, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.
Access: You have the right to ask for a copy of
the personal data that RECHARGE holds about
you free of charge, however we may charge a ‘reasonable fee’ if we think that your request is excessive, to help us cover the costs of locating
the information you have requested. We will respond to your request as soon as possible and (save for in certain circumstances) within one month. Correction: If there are any inaccuracies
in the information we hold about you, please contact us and we will correct them. Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you
may request that we delete it. Please note that
this may not always be possible due to legal obligations. Restrictions on use: You may
request that we stop processing your personal
data (other than storing it), if: (i) you contest
the accuracy of it
(unless the accuracy is verified);
(ii) you believe the processing is against the law;
(iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your data
to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
Object: You have the right to object
to processing of your personal data 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 data 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 the transfer: If you wish to transfer
your personal data to another organisation (and certain conditions are satisfied), you may
ask us to do so, and we will send it directly if we have the technical means. Please 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. Withdrawal of consent: If you previously gave us your
consent to allow us to process your personal
data for a particular purpose, but you no longer wish to consent to us doing so, you can contact
us to let us know that you withdraw that
consent. 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.
7. COOKIES
Our website uses cookies. A cookie is a small
file of letters and numbers stored by computer after being sent to your computer when you
visit a website. Whenever you visit the same website again, the information stored in the
cookie can be retrieved to notify the website
of your previous activity. We use cookies to facilitate website navigation,
maintain quality of online service, provide additional security, sending emails, allow the customisation
of your access to the website and remember
you when you return to the website. A cookie cannot give us access to your computer or to information beyond what you provide us and
we don’t store personally identifiable
information such as your name or address in
cookies we create, but we do use encrypted information gathered from them to help
improve your experience of the website. If you don’t wish to enable cookies, you’ll still
be able to browse the website and use it for research purposes. You can choose to have your computer warn you each time a cookie is
being sent, or you can choose to turn
off/on certain cookies. You do this through your web browser settings. Each browser is different,
so look at your browser Help menu to learn the correct way to modify your cookie settings.
Cookies and Similar Technologies
First and Third-Party Cookies
A “cookie” is a small file created by a web
server that can be stored on your device (if you allow)for use either during a particular
browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily
stored on your hard drive and only last until
they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain
stored on your hard drive until they expire
or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and
navigation to, from, and on a website.
First-party cookies are set by the website
you’re visiting, and they can only be read
by that site. Third-party cookies are set
by a party other than that website.
Other Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet
tags, web beacons (clear gifs, pixel tags, and
single-pixel gifs), and navigational data
collection (log files, server logs, etc.) that can
be used to collect data as users navigate
through and interact with a website:
-- Web beacons: These are tiny graphics
(sometimes called “clear GIFs” or “web pixels”)
with unique identifiers that are used to
understand browsing activity. In contrast to
cookies, which are stored on a user’s device,
web beacons are rendered invisible on web
pages when you open a page.
-- Social Widgets: These are buttons or icons provided by third-party social media platforms
that allow you to interact with social media services when you view a webpage or mobile
app screen. These social widgets may collect browsing data, which may be received by the
third party that provided the widget and are controlled by third parties.
-- UTM Codes: These are strings that can
appear in a URL (the “Uniform Resource
Locator,” which is typically the http or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across
different websites and other online services
may be associated with your personal
information and used to provide you with
targeted content. We do not control these
third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible
party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies,
you may choose to not allow certain cookies
via a cookies consent banner or you may set
your browser to refuse all or some types of
cookies or to alert you when cookies are being
sent by website tracking technologies and advertising.
Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the
cookie settings on the Site may not fully delete
all of the cookies that have already been
created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site.
8. DATA RETENTION
We will only retain your personal data for
as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in
the event of a complaint or if we reasonably believe there is a prospect of litigation in
respect to our relationship with you.
To determine the appropriate retention
period for personal data, we consider the
amount, nature and sensitivity of the personal
data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention
periods for different aspects of your personal
data are available in our retention policy
which you can request from us by contacting us.
We retain and use your information for as
long as is necessary to fulfill the purposes for which it was collected, to comply with our
business requirements and legal obligations, to resolve disputes, to protect our assets, to
provide our services, and to enforce our agreements.
We may delete your information if we believe
it is incomplete, inaccurate, or that our
continued storage of it is contrary to our
objectives or legal obligations. When we delete data, it will be removed from our active servers
and databases, but it may remain in our archives when it is not practical or possible to delete it.
To the extent permitted by law, we may retain
and use anonymous, de-identified, or
aggregated information for performance
reporting, benchmarking, and analytic purposes
and for product and service improvement.
HOW DO WE PROTECT YOUR
INFORMATION?
We have put security measures in place to
protect the personal information that you share with us from being accidentally lost, used,
altered, disclosed, or accessed in an
unauthorized manner. From time to time, we
review our security procedures to consider appropriate new technologies and methods.
While our security measures seek to protect
the personal information in our possession, no security system is perfect, and no data
transmission is 100% secure. As a result, while
we strive to protect your information, we
cannot guarantee or warrant the security
of any information transmitted to or from
the App or the Site. Your use of the App and
the Site is at your own risk. We cannot
guarantee that your data will remain secure in
all circumstances.
The safety and security of your personal information also depends on you. Where you
use a password for access to the App, you are responsible for keeping the password
confidential. Do not share your password with anyone. You should also take care with how you handle and disclose your personal information
and should avoid sending personal information through unsecure email.
If a data breach compromises your personal information, we will notify you and any
applicable regulator when we are required to
do so by applicable law.
YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION
Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law.
Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at ____________________________ and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Please note that Registered Users on the App cannot opt out of receiving transactional e-mails related to their account.
Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information.
If you have created a user account for the App, you may access, review, and make changes to your User Registration or Payment Information by following the instructions in the App. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and
about children on the Internet. Our App, Site
and services are not directed to children aged
13 or younger, nor is information knowingly collected from children under the age of 13. No
one under the age of 13 may access, browse, or
use the App or the Site or provide any
information to or on the App or the Site. If
you are under 13, please do not use or provide any information on the App or the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent,
we will take steps to stop collecting that information and delete it. If you believe we
might have any information from or about a
child under the age
of 13, please contact us via the “Contact Us”
details provided at the end of this Policy.
For more information about COPPA, please visit
the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
CONTACT US
For more information, or if you have any questions or concerns regarding this Policy, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.
Privacy policy
