Last updated: October 1, 2021
When we use the term “Personal Information” we mean any information that we collect on or in connection with the Services that would allow someone to identify you or contact you, such as your full name, address, email address, payment card information or telephone number. When we use the term “Additional Information”, we mean any information that we collect about you through the Services other than Personal Information. Additional Information may include, but is not limited to, Device type, Device operating system version, app or site version. Personal Information and Additional Information shall be collectively referred to as “Information”.
HOW WE COLLECT AND USE PERSONAL INFORMATION
INFORMATION YOU PROVIDE
If you elect to become a registered user of the Services, we will require you to provide certain Information, which may include, but not be limited to, your email address, legal name, telephone number(s), company name, etc., and, in order to conduct fee-based transactions and other activities, your physical address, applicable payment data (e.g., payment card number and expiration date), etc. (collectively, a “User Account”). We use and store this information so that we can create your account, verify access to your User Account across devices and across instances of the Services, for the prevention and detection of fraudulent access to your account, and to contact you regarding the administration of any features or functions of the Services.
Features, Functions and Communications. The Site may provide you with access to certain Services which may be subject to Additional Terms, including, without limitation, notices, requirements and settings, which may require that you provide certain Information about yourself in order to personalize and/or allow you to use these Services. In addition, you may be presented with the opportunity to sign up to receive newsletters, email communications, or other communications from us in order for us to provide up-to-date information about the Services, and to publicize and promote certain content, products and services offered by us or our business partners. When there is a separate sign-up for newsletters, we may ask for your contact information such as name and email address, and, sometimes, demographic and profile information. We may also use your Personal Information to access your Account in order to address any technical support requests. For any communications, whether it be a newsletter, support request, or any other email, we will ask you to confirm your consent to these uses at the time you sign up for these communications.
INFORMATION WE COLLECT AUTOMATICALLY
Our Services include features that automatically collect your Internet protocol (IP) address and Additional Information regarding your visits to the Site and use of the Services to assist us in keeping track of your preferences, create a more tailored user experience and better serve your particular interests and needs.
We may receive information about your current location, which we get from signals such as your IP address or Device settings. Subject to your settings, we may use your location data in order to customize and improve the Services. We will ask your permission to use your location data, and you can control your location preferences directly from your Device’s settings, or website browser settings.
Cookies and Tracking Technologies
This Services may also use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties to, for example, serve advertisements on the Services, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on the Services. Such services may enable us to display advertisements based on your use of the Services and other websites you have visited. Targeting services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.
You may have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. For example, if you are using Internet Explorer, search for “Cookies” in the Help menu to find detailed instructions. If you choose to decline cookies, you may not be able to use interactive features of this Site or other Websites that depend on cookies.
SHARING AND DISCLOSURE OF PERSONAL INFORMATION AND OTHER INFORMATION
Service Providers and Vendors
We may disclose your Personal Information to third parties, service providers, vendors, and affiliates for the purpose of administering and maintaining the Services, and other features, functions and operations in connection therewith. We will refer to these parties in this context as “Site Service Providers”. We use Site Service Providers to efficiently provide the full range of content, activities, services, features and functions we bring you and we disclose your Information to Site Service Providers for the purpose of providing services to us. These Site Service Providers may temporarily store some information on their servers, but they may only use your Personal Information to provide us with a specific service and not for any other purpose and agree to keep such Personal Information secure and confidential.
Business Transfers and Sale
We may use your Personal Information if we are legally obligated to assist in an investigation, court order, laws and regulations, to protect and defend our rights and property, to enforce our Terms of Service, agreements with third parties, the rights and safety of third parties, or any other required legal process. We will only process your Information in this manner to comply with any applicable laws.
There may be instances when we may access or disclose Information without providing you a choice in any of the following circumstances:
(a) To protect or defend the legal rights or property of Company, our affiliated companies or their employees, agents and contractors (including enforcement of our agreements)
(b) To protect the safety and security of our site, the Services and users
(c) Protect against fraud or for risk management purposes; or
RETAINING YOUR PERSONAL INFORMATION
We will retain the Personal Information submitted for your User Account as long as you maintain an account associated with any of our Services or as is necessary to provide you the Services including newsletters and email communications.
We will maintain Additional Information as long as is legally permissible in order to improve the performance and features of the Services that we provide.
Your Personal Information will be retained as necessary to comply with any applicable federal, state or local law and to conduct legitimate business activities, obligations, resolve disputes, and to enforce all of our agreements.
USER CHOICE; WITHDRAWAL OF CONSENT; DELETING PERSONAL DATA
This section sets out the procedure for accessing, viewing, modifying and deleting your Personal Information. You always have the right to access and correct the Personal Information you have provided and generally you may review, update or delete certain information collected by the Services at any time by following the instructions below.
Accessing, Modifying, and Deleting Your User Account
If you have registered a User Account on any of our Services and you need to access, view, correct, or modify your Personal Information associated with that account, we provide you with tools to do so in the account settings. If you would like to permanently delete your User Account, you can do so by emailing firstname.lastname@example.org and requesting that your User Account and the associated Personal Information be deleted. We will respond to all such requests within 15 business days.
If you would like to stop sharing your location data with us at any time you can disable location services on your Device or browser. These preferences can be found within the settings of your Device or browser. Instructions to change your preferences vary based on the type of Device or browser you are using.
If you would like to download the Personal Information you have sent to the Services at any time, you can do so by emailing us at email@example.com. We will respond to all such requests within 15 business days.
Recipients who have consented to receive such communications can unsubscribe by either following the specific instructions included in such communications or you may “opt-out” of receiving marketing and promotional emails from us at any time by sending an email to us at firstname.lastname@example.org detailing your privacy request. Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt out or unsubscribe cannot be retrieved or rescinded by us unless required by applicable law, and you cannot retroactively opt out or unsubscribe with respect to such third parties. We may also have features that allow you to submit information, questions or feedback to us. In those instances, we may retain your emails and other information you submit to us for our internal purposes, and to help us and our service providers serve you better.
While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information. However, regardless of our efforts and the Device you use to access the Services, it is possible that third parties may unlawfully intercept or access transmissions or private communications over an unsecured transmission. We also limit access to the Services by our own employees, contractors, Site Service Providers and those individuals who are authorized for the proper handling of such information. We request that our third party contractors and Site Service Providers follow similar standards of security and confidentiality.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as “unsubscribe”) or opt-in for use of your Personal Information by third parties for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your Personal Information for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices, please send a request by email to our Privacy Administrator at email@example.com or by postal mail to:
Attn: Your California Privacy Rights
26 1st Street #8153
Pelham, NY 10803
All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or postcard. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and email address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Links to Third-Party Websites
Social Media Platforms
Our Websites include features that link to or have integrations with various social media platforms (i.e. Facebook and Twitter). These features may collect your IP address, which page you visit on our site, and may set a cookie to ensure proper functionality. Social media features are either hosted by a third party or hosted directly on our website. Any Personal Information, communications, or materials you send via social media is done at your own risk, without a guarantee of privacy, as the actions of users on these platforms, and the platform itself, are not under our control. Your engagement with those features and platforms are governed by the privacy policies of the companies that provide them.
End Users Information
End users are defined as users whose personal information you may import into ClickEasy or otherwise collect via your ClickEasy website or emails (“End Users”). We may collect, store, and process certain information about your End Users, and this information will be used only for the purpose of providing the ClickEasy services. For example, we may collect the names and emails from End Users that sign up on your website, or through our email import functionality. ClickEasy does not sell, modify, or transfer any End User Personal Information.
In cases like this, ClickEasy serves as the “Data Processor” (as defined in the European Union General Data Protection Regulation) of such End User information. You shall be considered the “Data Controller” of any such End User Personal Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Personal Information, including all privacy and data protection laws of all relevant jurisdictions.
You, as the user, are responsible for the security, integrity, and authorized usage of the Personal Information of your End Users, and for obtaining consents, permissions, and providing any fair processing notices required for the collection and usage of such information.
We do not knowingly and actively collect Personal Information from children under the age of 13. If you have reason to believe that any child under this age (or the minimum age based on your country/region or local law) has provided their Personal Information to us, please contact us at firstname.lastname@example.org and we will take steps to delete that Information and any associated User Accounts.
The Services are controlled, operated and administered in the United States, and data is stored on servers both in the United States and Canada. The Services are intended for use only by Users within the United States.
Attn: Privacy Concerns
26 1st Street #8153
Pelham, NY 10803