Privacy Policy

Last updated and effective as of 20 February 2024. 

California Notice at Collection: For California residents, see the California Notice at Collection below for important information about your rights under California law.

This Privacy Policy describes how Brox.ai, Inc.AI (“Brox.aiAI,” “we”, “us” or “our”) processes personal information that we collect through our website at https://brox.ai/ and any other digital properties that we own or control and that posts or links to this Privacy Policy (collectively, the “Website”), as well as through social media pages, our marketing activities and other activities described in this Privacy Policy.

Brox.ai provides market research and syndicated products and services to enterprise business customers. This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing our products and services to them.

California users: For California residents, please read the “Your California privacy rights” section below in addition to the other sections of this Privacy Policy for information about your personal information and your privacy rights.

European users: If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please read the “Notice to European Users” section below in addition to the other sections of this Privacy Policy for information about your personal information and your privacy rights.

Index


Personal information we collect

Information you provide to us.

Personal information you may provide to us through the Website or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

  • Account data, such as the username and password that you may set to establish an online account with us, photograph or picture, links to your profiles on social networks, and any other information that you add to your account profile. 

  • Communications data based on our exchanges with you, including when you contact us through the Website, social media, or otherwise.

  • Survey data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. 

Automatic data collection.

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Website, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

  • Online activity data, such as pages you viewed, how long you spent on a page, the website you visited before browsing to the Website, navigation paths between pages, information about your activity on a page, access times and duration of access, and whether you have opened our emails or clicked links within them.

  • Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, including with respect to controlling cookies and similar technologies, see our Cookie Notice

Information we receive from other sources.

From time to time, we may obtain information about you from third party sources, such as public databases and websites, resellers and distributors, joint marketing or business partners, security and fraud detection firms and social media platforms. Examples of the information we may receive from other sources include: account information; page-view information; contact information from business partners with whom we operate events, sales and marketing campaigns, or joint offerings; search results and links, including paid listings (such as sponsored links); and credit history information from credit bureaus.


How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Website delivery and operations.

We may use your personal information to:

  • provide, operate, and improve the Website and our business;

  • personalize the Website, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Website;

  • establish and maintain your user account;

  • communicate with you about the Website, including by sending Website-related announcements, updates, security alerts, and support and administrative messages;

  • understand your needs and interests, and personalize your experience on the Website and our communications; and

  • provide support for the Website, and respond to your requests, questions and feedback.

Research and development.

We may use your personal information for research and development purposes, including to analyze and improve the Website and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business.

Direct marketing.

We and our service providers may send you Brox.AI-related or other direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of communications section below.   

Targeted online advertising

We may use one or more third party service providers to serve ads about our products and services on other websites. These third parties may automatically collect and use certain information about your online activities, either on the Website or other websites, such as your IP address, your ISP and the browser you are using. They may collect your information by using cookies and similar tracking technologies such as pixel tags and clear GIFs. We use the information collected, alone or in combination with information about you that we obtain from other sources (as described above), to among other things, deliver advertising targeted to your interests, including serving ads related to our products or services when you access and use other websites, and to better understand the usage of the Website as tracked by these third parties. This Privacy Policy does not apply to, and we are not responsible for, cookies or other similar technology such as pixel tags or clear GIFs, in ads delivered by third parties on other websites.

Website improvement and analytics.

We may use your personal information to analyze your usage of the Website, improve the Website, improve the rest of our business, help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection.

We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;

  • enforce the terms and conditions that govern the Website; and

  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft. 

With your consent.

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 


How we share your personal information

We may disclose your personal information to the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection. 

Service providers.

Third parties that provide services on our behalf or help us operate the Website or our business (such as information technology, customer support, email delivery, marketing, research and analytics). Linked third-party services. If you log into the Website with, or otherwise link your account to, a third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors.

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others.

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees.

Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Brox.AI (including, in connection with a bankruptcy or similar proceedings).


Your choices

In this section, we describe the rights and choices available to all users. Users who are California residents can find additional information about their rights in the “Your California privacy rights” section below. Users who are located in Europe can find additional information about their rights in the “Notice to European Users” section below.

Access or update your information.

If you have registered for an account with us through the Website, you may review and update certain account information by logging into the account.

Opt-out of communications.

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us using the information in the “How to contact us” section below. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Cookies

For information about cookies and similar technologies employed by the Website, including and how to control them, see our Cookie Notice

Blocking images/pixel tags/clear gifs:

In addition to the “Cookies” section above, Mmost browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track.

Some iInternet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track”. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information.

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms.

If you choose to connect to the Website through a third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.


Other sites and services

The Website may contain links to third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions, nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.


Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.


International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. 

Users in Europe should read the important information provided in the Notice to European Users below about the transfer of personal information outside of Europe.


Children  

The Website is not intended for use by anyone under 16 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Website from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.


Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Website after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Website and our business.


How to contact us

  • Email: privacy@brox.ai   

  • Address: Brox.ai, Inc., 1734 Granville Avenue, Los Angeles, CA 90025


Your California privacy rights

This section applies only to California residents. It describes how we collect, use, disclose and share personal information of California residents in operating our business, and their rights with respect to that personal information. For purposes of this section, “Personal Information” means personal information protected by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), but does not include data exempted from the scope of the CCPA.

Your California privacy rights.

As a California resident, you have the rights listed below. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.

  • Information. You can request information about the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting, sharing and/or selling Personal Information; the categories of any Personal Information that we sold or disclosed for a business purpose; and the categories of any third parties with whom Personal Information was sold, shared or disclosed for a business purpose.

  • Access. You can request a copy of the Personal Information that we have collected about you.

  • Deletion. You can ask us to delete the Personal Information that we have collected from you.

  • Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

  • Opt-out. You can opt-out of the sharing of your Personal Information for cross-contextual behavioral advertising purposes and/or from the sale of your Personal Information for monetary or other valuable consideration (as applicable).

  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights. 

How to Exercise Your Rights

Identity verification.

We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into your account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email address used to make the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.

Authorized agents.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

Information practices.

The following describes our practices currently and during the past 12 months:

  • Sale and sharing of Personal Information. We do not sell Personal Information in the traditional sense of exchanging information for monetary payment. However, because the definitions of “sharing” under the CCPA may include the disclosure of your information to certain types of marketing partners, we provide California residents with the right to opt-out of any such sharing of their Personal Information. As noted elsewhere in this Privacy Policy, we may disclose or make available Identifiers or Internet or other similar activity to providers that support marketing, research, and analytics. We allow you to opt out of such disclosures, as they may constitute “sharing” as defined under the CCPA. See the “How to exercise your rights” section above for more information on this topic.

  • Sensitive personal information. We do not use or disclose sensitive personal information (as that term is defined under CCPA) for purposes that California residents have a right to limit under the CCPA.

  • Deidentified data. We do not to attempt to reidentify deidentified information that we derive from Personal Information except that we may do so to test whether our deidentification processes comply with applicable law.

  • Retention. Our criteria for deciding how long to retain Personal Information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this Privacy Policy, including complying with our legal obligations. 

  • Sources and purposes. We collect all categories of Personal Information from the sources, use them for the business purposes described in the Personal information we collect and How we use your personal information sections above, and disclose them for the business and commercial purposes described in the How we share personal information section above.

  • Collection and disclosure. The chart below describes the Personal Information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose Personal Information for business purposes. The terms in the chart refer to the categories of information and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below. We may also disclose Personal Information to professional advisors, authorities and others, and business transferees as described above in the How we share personal information section above.

Statutory category/Personal Information we collect

Categories of third parties to whom we disclose the Personal Information for a business purpose

Identifiers

  • Contact data

  • Account data

  • Communications data

  • Marketing data

  • Third-party sources data

  • Survey data

  • Service providers

  • Linked third-party services

California Customer Records
(as defined in California Civil Code §1798.80)

  • Contact data

  • Account data

  • Communications data

  • Marketing data

  • Third-party sources data

  • Survey data

  • Service providers

  • Linked third-party services

Commercial Information

  • Communications data

  • Service providers

Internet or Network Information

  • Device data

  • Online activity data

  • Communication interaction data

  • Service providers

  • Linked third-party services

Inferences

May be derived from any of the above categories

  • Service providers

  • Linked third-party services

Notice to European users

General

Where this Notice to European users applies.

The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller.

Personal information.

References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.   

Controller.

Brox.AI is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (including the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the How to contact us section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to process your personal information to deliver our Website to you (“Contractual Necessity”).

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”). 

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see How we use your personal information above.

Notice to European users

General

Where this Notice to European users applies.

The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller.

Personal information.

References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.   

Controller.

Brox.AI is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (including the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the How to contact us section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to process your personal information to deliver our Website to you (“Contractual Necessity”).

  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”). 

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see How we use your personal information above.

Purpose

Categories of personal information involved

Legal basis

Website delivery and operations

  • Contact data

  • Account data

  • Communications data

  • Survey data

Contractual Necessity.

Website delivery and operations

  • Any and all data types relevant in the circumstances

Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.

Direct marketing and targeted online advertising

  • Contact data

  • Communications data

  • Marketing data

  • Survey data

  • Device data

  • Survey data

  • Online activity data

  • Communications interaction data

Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.

Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Compliance and protection

  • Any and all data types relevant in the circumstances

Compliance with Law.

Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Further uses

  • Any and all data types relevant in the circumstances

The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the pPersonal iInformation was collected.

Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information.

You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Website to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our services to you. We will notify you if this is the case at the time.

Sensitive personal information.

We will collect your consent to process and use any sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Website or otherwise share sensitive personal information with us.

No automated decision-making and profiling.

As part of the Website, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy. affecting your personal information.

Your rights

European data protection laws give you certain additional rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct. Update or correct inaccuracies in your personal information.

  • Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

  • Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.

  • Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.

  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. 

Exercising These Rights.

To exercise any of these rights, please refer to the “Your choices” section above or contact us using the contact details provided under the “How to contact us” section above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority.

Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

  • For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

  • For users in the UK – the contact information for the UK data protection regulator is below:

    The Information Commissioner’s Office
    Water Lane, Wycliffe House
    Wilmslow - Cheshire SK9 5AF
    Tel. +44 303 123 1113
    Website: https://ico.org.uk/make-a-complaint/

Data processing outside Europe 

We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Website, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe. 

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).

  • Transfers to territories without an adequacy decision.

    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection

    • However, in these cases:

      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or

      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information.

You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Website to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our services to you. We will notify you if this is the case at the time.

Sensitive personal information.

We will collect your consent to process and use any sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Website or otherwise share sensitive personal information with us.

No automated decision-making and profiling.

As part of the Website, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy. affecting your personal information.

Your rights

General. European data protection laws give you certain additional rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct. Update or correct inaccuracies in your personal information.

  • Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

  • Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.

  • Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.

  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. 

Exercising These Rights.

To exercise any of these rights, please contact us using the contact details provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority.

Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

  • For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

  • For users in the UK – the contact information for the UK data protection regulator is below:

    The Information Commissioner’s Office
    Water Lane, Wycliffe House
    Wilmslow - Cheshire SK9 5AF
    Tel. +44 303 123 1113
    Website: https://ico.org.uk/make-a-complaint/

Data processing outside Europe 

We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Website, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe. 

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the US legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).

  • Transfers to territories without an adequacy decision.

    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US, see above). 

    • However, in these cases:

      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or

      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes. 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, 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. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other information

No obligation to provide personal information.

You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Website to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our services to you. We will notify you if this is the case at the time.

Sensitive personal information.

We will collect your consent to process and use any sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Website or otherwise share sensitive personal information with us.

No automated decision-making and profiling.

As part of the Website, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy. affecting your personal information.

Your rights

General. European data protection laws give you certain additional rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct. Update or correct inaccuracies in your personal information.

  • Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

  • Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.

  • Object. Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.

  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. 

Exercising These Rights.

To exercise any of these rights, please contact us using the contact details provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority.

Although we urge you to contact us first to find a solution for any concern you may have, in addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

  • For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

  • For users in the UK – the contact information for the UK data protection regulator is below:

    The Information Commissioner’s Office
    Water Lane, Wycliffe House
    Wilmslow - Cheshire SK9 5AF
    Tel. +44 303 123 1113
    Website: https://ico.org.uk/make-a-complaint/

Data processing outside Europe 

We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Website, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe. 

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the US legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

  • Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).

  • Transfers to territories without an adequacy decision.

    • We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US, see above). 

    • However, in these cases:

      • we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or

      • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.