YOUR PRIVACY RIGHTS UNDER GDPR
This Supplemental Privacy Notice applies to individuals (“you”, “your”, “data subject”) in the European Economic Area (“EEA”), United Kingdom (“UK”) and Switzerland and supplements our main Privacy Notice. You have certain data privacy rights, as defined by the General Data Protection Regulation (“GDPR”), as adopted and applied in the EEA, UK and Switzerland. Your privacy rights relative to your relationship with our Company may vary depending on circumstances, as described below. References to “Services” below apply to our website and our social media channels. This Notice is incorporated into and forms part of our Privacy Notice.
Legal Basis for Processing Personal Information If you’re a resident of or are located within the EEA, UK or Switzerland, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform or undertaking marketing.
How Long We Keep Your Information For
We will keep your personal information for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Where We Store or Process Your Information
The information we collect from you may be transferred to, processed, and stored at, a destination outside the US, namely the EEA, UK or Switzerland. Specifically, our servers are located in the US, but when we collect your personal information, we may process it in another country. Such destinations or countries may not have laws which protect your information to the same extent as in your home country. It may be processed by us or by our service providers operating outside the US, EU, or UK, but we will take appropriate steps to ensure that your information is treated securely and in accordance with this Privacy Notice.
Privacy Rights for Individuals Communicating with Company Directly
For data subjects who communicate directly with the Company via digital media (i.e., email, our Contact Us form, direct messages through our Services, phone, fax, etc.), your privacy rights include the following:
● Access: You have the right to request that we provide you access to a copy of your personal data held by us.
● Correction, Amendment and Deletion: You have the right to request a correction or amendment of your personal data held by us. You also have a right to request that we delete certain personal data about you.
● Restriction: You have the right to request that we restrict processing of your personal data held by us if you contest the accuracy of your personal data held by us or the lawfulness of Company’s processing of your personal data.
● Portability: You have the right to receive your personal data held by us in a structured, commonly used and machine-readable format. You also have the right to transmit your personal data to another organization without hindrance from us.
● Objection: You have the right to object, on grounds relating to your particular situation, to Company’s processing of personal data about you, unless we demonstrate compelling legitimate grounds for continuing such processing. You also have the right to object to any automated decision-making (such as user profiling) used by us.
● Right to Further Information: You have the right to obtain, upon request, further information necessary for the exercise of these rights.
● Complaints: You have the right to lodge a complaint or concern about our data privacy practices with us directly and/or with an appropriate supervisory authority.
● Withdraw Consent: You have the right to withdraw your consent at any time where Company relied on your consent to process your Personal Information. However, processing activities based on your consent in the past will not become unlawful as a result of your revocation.
If you wish to exercise any of your rights, as described above, please submit your request to us by using the information in the How to Contact Us section in our main Privacy Notice. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
How to Lodge a Complaint Under GDPR and UK GDPR
If you are in the EEA and wish to lodge a complaint about our data privacy practices with a regulatory authority in your country, you can find details at this link: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.
If you are in the UK and wish to lodge a complaint about our data privacy practices with a regulatory authority in your country, you can find details at this link: https://ico.org.uk/global/contact-us/
If you are in Switzerland and wish to lodge a complaint about our data privacy practices with a regulatory authority in your country, you can find details at this link:
dataprivacy@switzerland.com.
UPDATES TO THIS NOTICE
We may update this supplemental notice from time to time. The latest version will always be available on our website.
