As of/in effect by: April 2019
COLLECTION OF INFORMATION
Provision of your personal information submitted to us is completely voluntary. “Personal information” is information that can specifically identify you. We do not collect personal information unless you submit that information to us. Categories of personal information we may collect include:
- Identity Data, which includes your name (and/or other similar identifiers).
- Contact Data, which includes your email address.
Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
- Technical Data, which includes internet protocol (IP) address, location data, and device and browser information.
- Usage Data, which includes information about how you use our Website and advertising we serve on this site.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
We use different methods to collect data from and about you including through:
Direct interactions: your information by contacting us; this includes information you provide when you:
- subscribe to our service or publications;
- request marketing to be sent to you; or
- give us feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data about you. Some of the ways in which we or our website may collect are further described below:
- Interest-Based Advertising: We may engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit 2gurly4u.com. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular subject, our vendor may cause an advertisement to appear on other websites you view with information on that subject. This form of advertising is called “behavioral advertising”. We believe that such advertising is helpful because you will see ads that are relevant to your interests.
- Clickstream Data: As you use the Internet, a trail of electronic information is left at each website you visit. This information, sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. For example, clickstream data can tell the type of computer and browsing software you use and the address of the website from which you linked to the website. The website may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website, how visitors navigate throughout the Website and how we may tailor our website to better meet the needs of visitors. This information often will be used to improve our website and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any personal information.
INFORMATION USE AND SHARING
Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below. Specifically, we use your information for a variety of purposes:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- To perform specific services that you have requested.
To respond to your direct inquiries.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To send you marketing materials (see below)
- Where we need to comply with a legal or regulatory obligation.
Subject to the section titled “Additional EU Disclosures”, we may share the information we collect about you with certain third parties in the following ways:
- Third parties to whom we may choose to sell, transfer, or merge with.
- Third parties to whom we need to share your information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the website.
THIRD-PARTY LINKS AND SOCIAL NETWORKING SERVICES
The Website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
We have put in place appropriate security measures to prevent information about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We have put in place procedures to deal with any suspected data breach that will affect you and will notify you and any applicable regulator of a breach where we are legally required to do so.
RETENTION OF DATA
We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
ADDITIONAL EU DISCLOSURES
OUR ROLE AS DATA CONTROLLER AND DATA PROCESSOR
Grace Agosta generally acts as the data controller of your information submitted through our website.
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us”. If you are situated in the EU and have a complaint, please contact us at firstname.lastname@example.org.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
COLLECTION OF PERSONAL DATA FROM THIRD PARTY SOURCES
We may collect personal data about you from various third parties and public sources.
- As discussed above, we may also obtain information through automated technologies (see section titled “Information Collection”)
WITHDRAWING YOUR CONSENT
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org.
USE OF YOUR PERSONAL DATA FOR MARKETING PURPOSES
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
OPTING OUT OF MESSAGES FROM US
If you do not want your personal information or personal data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email to email@example.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of the Website may no longer be available to you.
OPTING OUT OF COOKIES
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Website or some of its functionality may be affected. Cookies and similar items are not used by us to automatically retrieve personally identifiable information from your device without your knowledge.
DATA RELATING TO CHILDREN
Our Website is designed for those 16 years of age and older. We do not knowingly collect information from anyone under the age of 13 (or such other age as may be restricted under local law).
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