This is a model text for client guidance and is not guaranteed by any legal or judicial means. Please contact your legal advisor or department for the correct development of the text.
Privacy Policy of [website name]
Introduction
This Privacy Policy summarizes the practices carried out by [add name of the corresponding company]
("us", "our" either "The Company") in relation to the information collected from users who access our website through [add corresponding address link]
("Place") or who share personal information with us (collectively: "Users").
Reasons for data collection
The processing of your Personal Information (i.e. any information which may allow your identification by reasonable means; (hereinafter "Personal information") [add explanation regarding the legal basis for processing the legal information, such as:]
It is necessary for the fulfillment of our contractual obligations to you, as well as to provide you with our services, protect our legitimate interests and comply with the legal and financial regulations to which we are subject.
By using the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.
We recommend that our Users read this Privacy Policy carefully and use it to make informed decisions.
What information do we collect?
We collect two types of data and information from Users.
The first type is non-personally identifiable and unidentifiable information about users that may be collected through your use of the Site ("Non-Personal Information"). We do not know the identity of a user from whom Non-Personal Information was collected. This information may include aggregated usage data and technical information provided by your device, both software and hardware (such as the type of browser and operating system your device uses, language preferences, access time, etc.), in order to improve the functionality of our Site. We also collect information about your activity on our Site (such as pages viewed, web browsing, clicks, actions, etc.).
The second type of information is Personal Information, which is individually identifiable information, that is, information that identifies an individual or that can, without undue difficulty, identify an individual. This information includes:
- Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (such as MAC addresses and UUIDs), and other information related to your activity on the Site.
- [add types of personal information collected, along with explanations, such as:]
- Registration Information: When you register on our Site, you will be asked to provide us with certain information, including your first and last name, email or postal address, and other information.
- …
- …
How do we receive information about you?
We receive your personal information from various actions or sources:
When you voluntarily provide us with your personal data when registering on our Site,
When you use our Site or make use of it in connection with your use of our services,
From external providers, services and public records (such as traffic statistics providers).
What information do we collect?
We do not rent, sell or share User information with any third party except as described in this Privacy Policy.
We may use the information for the following purposes:
- [add detailed usage types, such as:]
- Maintaining communication with you: to send you notifications related to our services, providing you with technical information and resolving any customer service issues you may have.
- Communicate with you and keep you informed about our latest services and updates.
- Show you advertisements when you use our Site (learn more in the "Ads" section).
- Market and promote our websites and products (learn more in the "Marketing" section).
- Conduct tests and statistical and analytical studies in order to improve the Site.
- …
In addition to the various uses listed above, we may transfer or disclose Personal Information to our affiliated companies and subcontractors.
Other than the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party vendors, who may be located in different jurisdictions around the world, for any of the following purposes:
- Host and manage our Site
- [Add and correct relevant third party types, such as:]
- Provide you with our services, including a personalized display of our Site
- Store and process such information on our behalf
- Serve you ads and assist you in both evaluating the success of our advertising campaigns and retargeting any of our users
- Provide you with commercial offers and promotional material related to our Site and our services
- Conduct research, technical diagnostics or analysis
In addition, we may disclose information if we have a reasonable belief that such disclosure is helpful or reasonably necessary to: (1) comply with any applicable law, regulation, legal process or governmental request; (2) enforce our policies (including our Agreement), including any investigation of potential violations thereof; (3) investigate, detect, prevent, or take action regarding illegal activities or other violations, suspected fraud or security matters; (4) establish or exercise our rights to defend against legal claims or allegations; (5) prevent harm or injury to the rights, property or safety of us, our users, you or any third party; or (6) cooperate with law enforcement agencies and/or, if we deem it necessary, enforce intellectual property or other legal rights.
User rights
You can request:
- Receive confirmation as to whether or not personal data concerning you is being processed, as well as access to your stored personal data, together with supplementary information.
- Receive a copy of the personal information you provide directly to us in a structured, commonly used and machine-readable format.
- Request rectification of your personal information over which we have control.
- Request deletion of your personal information.
- Object to our processing of your personal information.
- Request restriction of our processing of your personal information.
- Submit a complaint or claim to a supervisory authority.
Please note, however, that these rights are not definitive and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the rights mentioned above, or to receive further information, please contact our Data Protection Officer ("DPO") using the details set out below:
[add contact details].
Data retention
We will retain your personal information for as long as necessary to provide our services, as well as to comply with our legal obligations, resolve disputes, and implement and enforce our policies. Retention periods will be determined taking into account the type of information collected and the purpose of such collection, taking into account the requirements applicable to the situation and the need to destroy outdated and unused information as quickly as possible. Subject to applicable laws, we will retain records containing personal information of customers, account opening documents, communications and any other information required by applicable laws and regulations.
We may rectify, replace or delete inaccurate information at any time and at our sole discretion.
Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A "cookie" is a small piece of information that a website assigns to your device when you visit or view that website. Cookies are very useful and can be used for a variety of purposes, including allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences, and speeding up and facilitating your interaction with our Services. Cookies are also used to ensure that the advertisements you see are relevant to you and your interests, and to compile statistical data about your use of our Services.
The Site uses the following types of cookies:
A. "Session Cookies", which are stored only temporarily during a browsing session in order to allow normal use of the system and which are deleted from the device when the browser is closed.
B. "Persistent Cookies"These are cookies that are only read by the Site, are stored on your computer for a certain period of time and are not deleted when you close your browser. This type of cookie is used when we need to recognise you for future visits, for example so that we can store your preferences for the next time you access the Site.
C. "Third-party cookies", which are cookies set by other online services that run content on the page you are viewing, such as third-party analytics companies that monitor and analyze our web access.
Cookies do not contain any information that personally identifies you, although we may link Personal Information we store about you to the information stored in and obtained from cookies. You can delete cookies by following the instructions in your device preferences, but if you choose to disable cookies, some features of our Site may not function properly and your online experience may be limited.
In addition, we use a tool called "Google Analytics" to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit, etc. We use the information we obtain from this tool solely to improve our Site and our services. Google Analytics collects the IP address assigned to you at the time of your visit rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to this Site is limited by the Google Analytics Terms of Use and the Privacy Policy. Google Privacy Policy.
Collection of information from third parties
Our policy only addresses the use and disclosure of information we collect from you. With respect to the disclosure of information you make to other parties or sites across the Internet, different regulations may apply to such disclosure or use of information. Accordingly, we encourage you to read the terms and conditions and privacy policy of each party to whom you choose to disclose information.
This Privacy Policy does not apply to the practices of companies that we do not own or control, or to any individuals not employed or directed by us, including any third parties who may disclose information as set forth in this Privacy Policy.
How do we protect your information?
We pay special attention to implementing and maintaining the security of both the Site and your information. [explain your security practices, such as: We use industry standard procedures and policies to ensure the security of the information we collect and store, and to prevent unauthorized use of it, and we require all third parties to implement similar security requirements, consistent with this Privacy Policy]. Although we take reasonable steps to secure information, we cannot be held responsible for the acts of anyone who gains unauthorized access to or misuses our Site, and we make no warranties, express, implied or otherwise, that such access will not be prevented.
Transfer of data outside the EEA
Please note that some recipients of your data may be located outside the European Economic Area. In such cases, we will only provide your data to countries whose level of data protection has been approved by the European Commission, or we will establish an agreement to ensure an adequate level of data protection.
Advertisements
We may use third-party advertising technology to serve ads when you access the Site. This technology uses your information regarding your use of the Services to serve ads to you (for example, by placing third-party cookies on your web browser).
[Add information regarding opt-out options from personalized ads, such as:]
You may opt out of many third-party advertising networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). To learn more about this practice by NAI and DAA members, as well as your choices regarding their use of your information, including how to opt out of third-party advertising networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
Marketing
We or our third party subcontractors may use your Personal Information, such as your name, email address, phone number, etc., for the purpose of providing you with promotional material relating to our services that we believe may be of interest to you.
Out of respect for your right to privacy, we also provide you with the means to opt out of receiving our commercial offers along with such material. If you unsubscribe, we will remove your email address or phone number from our commercial distribution lists.
Please note that even if you have opted out of receiving our commercial emails, we may still send you other types of important email communications without offering you the option to opt out. These communications may include customer service announcements or administrative notices.
Corporate transaction
We may share information in the event of a corporate transaction (such as the sale of a substantial portion of our business, a merger, or an asset sale). In such a case, the acquiring company will have the rights and obligations described in this Privacy Policy.
Minors
We understand the importance of protecting children's privacy, especially in an online environment. The Site is not designed or intended for use by children. Under no circumstances will we permit use of our services by minors without prior consent or authorization from a parent or legal guardian. We do not knowingly collect any Personal Information from minors. If a parent or legal guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us via [add relevant email address].
Updates or modifications to this Privacy Policy
We reserve the right to periodically modify or revise the Privacy Policy, which changes will be effective upon posting of the revised or modified Privacy Policy. The latest revision will be reflected in the "Last Modified" section. Your continued use of the Platform following notification of such modifications on our website constitutes your acknowledgement of and consent to such modifications to the Privacy Policy and your agreement to be bound by the terms of such modifications.
How to contact us
If you have any general questions about the Site or the information we collect from you and how we use it, you can contact us at [add relevant email address].