Latest update: May 21st, 2020
As part of our privacy and cookies policy we will obtain personal data about you such as your name and address whenever you complete an online form. For example, we will obtain your personal data when you contact us for any reason. We may also obtain sensitive personal data about you if you volunteer it during the completion of an online form. If you volunteer such information, you will be consenting to our processing it for the purpose of dealing with your request.
How we may use your personal data
We will use your personal data for the purposes described in the data protection notice that was given to you at the time your data were obtained. These purposes include:
- to help us identify you and any accounts you hold with us
- statistical analysis
- customer profiling and analysing your purchasing preferences
- marketing – see ‘Marketing and opting out’ below
- fraud prevention and detection
- customising this website and its content to your particular preferences
- improving our services
Marketing and opting out
Unless you have asked us not to do so, we may contact you by mail, telephone, SMS, text/picture/video message, fax, email) about any of our services which may be of interest to you. If you prefer not to receive any further marketing communications from us, you can opt out at any time. See further ‘Your rights’ below.
Sharing your data with Third Parties
We will never sell your Personal Data to any third party. We don’t trade, share or transfer your personal data to third parties except in the following limited circumstances:
- We may share your personal data with our parent companies, subsidiaries, and affiliates;
- We may share your personal data with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, customer support, data analytics, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Offerings, among other things. For example, we may provide personal data to our service providers for direct emailing of our newsletters or notifications of our product/service offerings;
- We may share your personal data when we have a good faith belief that access, use, preservation or disclosure of such data is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
- We may share your personal data with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
- We may share your personal data with our business partners who offer a service to you jointly with us, for example when running a cross-promotion;
- We may share and/or transfer your personal data if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets; and
- We may share your personal data with a third party if we have your consent to do so.
- We may also share aggregated or anonymised data with third parties for other purposes. Such data does not identify you individually but may include usage, viewing and technical data such as the types of Offerings our customers and users generally use, the configuration of their computers, and performance metrics related to the use of Offerings which we collected through our technology. If we are required under applicable law to treat such data as personal data, then we will only disclose it as described above. Otherwise, we may disclose such data for any reason.
Keeping your data secure
We are committed to protecting your personal information against unauthorized use or disclosure.
We implement a variety of security measures to maintain the safety of your personal information when you access your personal information. We do not sell, trade or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, regulation or legal request; enforce our site policies or protect ours or others rights, property or safety or to detect, prevent, or otherwise address fraud, security or technical issues. However non-personally identifiable visitor information may be provided to other parties for marketing or other uses. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy.
Whilst we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet.
Information about other individuals
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his or her personal data
- receive on his/her behalf any data protection notices
Your Controls and Choices
We may provide you with the opportunity to “opt-out” of having your personal data used for certain purposes when we ask for this data. If you decide to opt-out, we may not be able to provide certain features of the Website to you.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Website. Please note, however, that customers cannot opt out of receiving transactional emails related to their account with us.
How We Respond to Do Not Track Signals
Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Website does not respond to this type of signal.
Accessing and Updating Your Personal Data
When you use the Offerings, we make good faith efforts to provide you with access to your personal data upon your request and either provide you the means to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your data at any time. To do so, please contact us at [email protected] with your name and the data requested to be accessed, corrected or removed. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning data residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide data access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
We may retain your data as necessary to operation function of our Website, comply with our legal obligations or resolve disputes.
Your Rights under General Data Protection Regulation (GDPR)
You may exercise certain rights regarding your Personal Data processed by GrowthClaps. In particular, you have the right to do the following:
- Withdraw your consent at any time. You have the right to withdraw consent where you have previously given it to the processing of your Personal Data.
- Object to the processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than consent.
- Access your Data. You have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
- Verify and seek rectification. You have the right to verify the accuracy of your data and ask for it to be updated or corrected.
- Restrict the processing of your data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, GrowthClaps will not process your data for any purpose other than storing it.
- Have your Personal Data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your data from GrowthClaps.
- Receive your data and have it transferred to another controller. You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.
- Lodge a complaint. You have the right to bring a claim before a data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in GrowthClaps or for the purposes of the legitimate interests pursued by GrowthClaps, you may object to such processing by providing a ground related to your particular situation to justify the objection.
You must know that, however, should your Personal Data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn, whether GrowthClaps is processing Personal Data for direct marketing purposes, you may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise your rights can be directed to GrowthClaps through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by GrowthClaps as early as possible and always within one month.
International Transfer of Data