PRIVACY POLICY

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Introduction

We (“we,” “us,” “our”) take the protection of the data of users (“Users” or “you”) of our website and/or our mobile app (the “Website” or the “Mobile App”) very seriously and are committed to protecting the information that Users provide to us in connection with their use of our Website and/or our Mobile App (collectively, the “Digital Assets”) to protect the information you provide to us in connection with your use of our Website and/or Mobile App. Furthermore, we are committed to protecting and using your data in accordance with applicable law.

This Privacy Policy explains our practices regarding the collection, use, and disclosure of your data through your use of our Digital Assets (the “Services”) when you access the Services via your devices.

Please read this Privacy Policy carefully and ensure that you fully understand our practices regarding your data before using our Services. If you have read and fully understood this Policy and do not agree with our practices, you must stop using our digital assets and Services. By using our Services, you acknowledge the terms of this Privacy Policy. Your continued use of the services constitutes your consent to this Privacy Policy and any changes to it.

In this Privacy Policy, you will learn:

• How we collect data

• What data we collect

• Why we collect this data

• With whom we share the data

• Where the data is stored

• How long the data is retained

• How we protect the data

• How we handle data from minors

• Updates or Changes to the Privacy Policy

 

What Data Do We Collect?

Below is an overview of the data we may collect:

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• Non-identified and non-identifiable information that you provide during the registration process or that is collected through your use of our services (“non-personal data”). Non-personal data does not allow us to determine who it was collected from. The non-personal data we collect consists primarily of technical and aggregated usage information.

• Individually identifiable information, i.e., any information that can be used to identify you or that could be used to identify you with reasonable effort (“personal data”). The personal data we collect through our services may include information requested from time to time, such as names, email addresses, mailing addresses, phone numbers, IP addresses, and more. When we combine personal data with non-personal data, we treat the combined data as personal data for as long as it remains combined.

How do we collect data?

Listed below are the main methods we use to collect data:

• We collect data when you use our services. So, when you visit our digital assets and use our services, we may collect, record, and store usage data, session data, and related information.

• We collect data that you provide to us yourself, for example, when you contact us directly through a communication channel (e.g., an email with a comment or feedback).

• We may collect data from third-party sources, as described below.

• We collect data that you provide to us when you sign in to our services through a third-party provider such as Facebook or Google.

 

Why do we collect this data?

We may use your data for the following purposes:

• to provide and operate our services;

• to develop, customize, and improve our services;

• to respond to your feedback, inquiries, and requests, and to offer assistance;

• to analyze demand and usage patterns;

• for other internal, statistical, and research purposes;

• to improve our data security and fraud prevention capabilities;

• to investigate violations and enforce our terms and policies, as well as to comply with applicable laws, regulations, or government orders;

• to send you updates, news, promotional materials, and other information related to our services. For promotional emails, you can decide for yourself whether you wish to continue receiving them. If not, simply click the unsubscribe link in these emails.

 

 

To whom do we disclose this data?

We may share your data with our service providers to operate our services (e.g., storing data via third-party hosting services, providing technical support, etc.).

 

We may also disclose your data under the following circumstances: (i) to investigate, detect, prevent, or take action against illegal activities or other misconduct; (ii) to establish or exercise our rights in our defense; (iii) to protect our rights, property, or personal safety, as well as the safety of our users or the public; (iv) in the event of a change of control at our company or at one of our affiliates (through a merger, acquisition, or purchase of (substantially) all assets, among other things); (v) to collect, store, and/or manage your data through authorized third-party providers (e.g., cloud service providers), to the extent reasonably necessary for business purposes; (vi) to collaborate with third-party providers to improve your user experience. To avoid any misunderstanding, we would like to point out that we cannot transfer, disclose, or otherwise use non-personal data to third parties at our sole discretion.

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Please note that our services enable social interactions (e.g., publicly posting content, information, and comments, and chatting with other users). We would like to point out that any content or data you make available in these areas may be read, collected, and used by others. We advise against posting or sharing information with others that you do not wish to make public. If you upload content to our digital assets or otherwise make it available while using a service, you do so at your own risk. We cannot control the actions of other users or members of the public who have access to your data or content. You acknowledge and hereby confirm that copies of your data may remain accessible even after deletion on cached and archived pages or after a third party has created a copy or stored your content.

 

Cookies and Similar Technologies

When you visit or access our services, we authorize third parties to use web beacons, cookies, pixel tags, scripts, and other technologies and analytics services (“Tracking Technologies”).

These tracking technologies may enable third parties to automatically collect your data to improve the browsing experience on our digital assets, optimize their performance, and ensure a personalized user experience, as well as for security and fraud prevention purposes.

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We may serve advertisements through our Services and our digital assets (including websites and applications that use our Services), which may be tailored to you—for example, ads based on your recent browsing behavior across websites, devices, or browsers.

 

To deliver these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or HTML5 local storage and/or other technologies. We may also use third parties, such as ad networks (i.e., third parties that display ads based on your website visits), to serve targeted ads. Third-party ad network providers, advertisers, sponsors, and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or Flash cookies and/or other technologies to measure the effectiveness of their ads and to customize advertising content for you. These third-party cookies and other technologies are subject to the specific privacy policy of the respective third party and not to this one.

 

Where do we store the data?

Non-Personal Data

 

Please note that our companies, as well as our trusted partners and service providers, are located around the world. For the purposes described in this Privacy Policy, we store and process all non-personal data we collect in various jurisdictions.

 

Category: Personal Data Collected from Users

 

Personal Data

Personal data may be maintained, processed, and stored in the United States, Ireland, South Korea, Taiwan, Israel, and, to the extent necessary for the proper provision of our services and/or as required by law (as further explained below), in other jurisdictions.

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How Long Is the Data Retained?

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Please note that we retain the collected data for as long as necessary to provide our services, comply with our legal and contractual obligations to you, resolve disputes, and enforce our agreements.

We may correct, supplement, or delete inaccurate or incomplete data at any time at our sole discretion.

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How do we protect the data?

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The hosting service for our digital assets provides us with the online platform through which we can offer our services to you. Your data may be stored using our hosting provider’s data storage systems, databases, and general applications. The provider stores your data on secure servers behind a firewall and offers secure HTTPS access to most areas of its services.

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Category: User Accepts Payments/eCom

All payment options offered by us and our hosting provider for our digital assets comply with the PCI-DSS (Payment Card Industry Data Security Standard) regulations of the PCI Security Standards Council. This is a collaboration among brands such as Visa, MasterCard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of credit card data (including physical, electronic, and procedural safeguards) by our store and service providers.

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Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and will not guarantee absolute protection or security of the data you upload, publish, or otherwise share with us or others.

For this reason, we ask that you set strong passwords and, whenever possible, refrain from sharing confidential information with us or others that, in your opinion, could cause you significant or lasting harm if disclosed. Since email and instant messaging are not considered secure forms of communication, we also ask that you refrain from sharing confidential information via any of these communication channels.

 

How do we handle minors?

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Category: User-Collected Data from Minors

Children may use our services. However, if they wish to access certain features, they may be required to provide certain information. Some data (including data collected via cookies, web beacons, and other similar technologies) may be collected automatically. If we knowingly collect, use, or disclose data collected from a child, we will provide notice and obtain parental consent in accordance with applicable law. We do not make a child’s participation in an online activity contingent on the child providing more contact information than is reasonably necessary for participation in that activity. We use the data we collect only in connection with the services the child has requested.

 

We may also use a parent’s contact information to communicate about the child’s activities on the services. Parents may review the information we have collected from their child, instruct us not to collect any further information from their child, and request that all information we have collected be deleted from our records.

 

Please contact us to view, update, or delete your child’s data. To protect your child, we may ask you to provide proof of your identity. We may deny you access to the data if we believe your identity is in question. Please note that certain data cannot be deleted due to other legal obligations.

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We use your personal data only for the purposes set forth in the Privacy Policy and only if we are convinced that:

• the use of your personal data is necessary to fulfill or enter into a contract (e.g., to provide you with the services themselves or customer service or technical support);

• the use of your personal data is necessary to comply with applicable legal or regulatory obligations; or

• the use of your personal data is necessary to support our legitimate business interests (provided that this is always done in a manner that is proportionate and respects your data protection rights).

As an EU resident, you may:

 

• request confirmation as to whether or not personal data concerning you is being processed, and request access to your stored personal data as well as certain additional information;

• request to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format;

• request the rectification of your personal data stored by us;

• request the erasure of your personal data;

• object to our processing of your personal data;

• request the restriction of the processing of your personal data; or

• file a complaint with a supervisory authority.

Please note, however, that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal data we collect and how we use it, please contact us as indicated below.

In the course of providing the Services, we may transfer data across borders to affiliated companies or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the Services, you consent to the transfer of your data outside the EEA.

 

If you are located in the EEA, your personal data will only be transferred to locations outside the EEA if we are satisfied that an adequate or comparable level of protection for personal data exists. We will take appropriate steps to ensure that we have adequate contractual arrangements in place with our third parties to guarantee that appropriate security measures are taken to minimize the risk of unauthorized use, alteration, deletion, loss, or theft of your personal data, and that these third parties act in accordance with applicable laws at all times.

Rights Under the California Consumer Privacy Act

 

If you use the Services as a California resident, you may be entitled under the California Consumer Privacy Act (“CCPA”) to request access to and deletion of your data.

 

To exercise your right to access and delete your data, please see below for information on how to contact us.

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We do not sell users’ personal data for the purposes defined by the CCPA.

 

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Users of the Services who are California residents and under the age of 18 may request and obtain the deletion of their published content by emailing the address provided below in the “Contact” section. All such requests must be labeled “California Removal Request.” All requests must include a description of the content you wish to have deleted, as well as sufficient information to help us locate the material. We do not accept notices that are not labeled or submitted properly, and we may not be able to respond if you do not provide sufficient information. Please note that your request does not guarantee that the material will be completely or comprehensively deleted. For example, material you have posted may be republished or reposted by other users or third parties.

 

Updates or Changes to the Privacy Policy

We may revise this Privacy Policy from time to time at our sole discretion; the version published on the website is always the most current (see the “Effective Date” notation). We ask that you review this Privacy Policy regularly for changes. In the event of material changes, we will post a notice on our website. If you continue to use the Services after we have posted notice of changes on our website, this constitutes your acknowledgment and acceptance of the changes to the Privacy Policy and your agreement to be bound by the terms of those changes.

 

Contact

If you have general questions about the Services or the data we collect about you and its use, please contact us via the website contact form or by email.

 

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DISCLAIMER

The information contained herein is not a substitute for legal advice, and you should not rely on it alone. Specific requirements regarding legal concepts and guidelines may vary from state to state and/or from legal system to legal system. As set forth in our Terms of Use, you are responsible for ensuring that your use of the Services is permitted under the law applicable to you and that you comply with it.

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To ensure that you fully comply with your legal obligations, we strongly recommend that you seek professional advice to better understand the specific requirements that apply to you.