5. DO WE USE COOKIES AND
OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other
tracking technologies to collect and
store your information.
We may use cookies and similar
tracking technologies (like web
beacons and pixels) to gather
information when you interact with our
Services. Some online tracking
technologies help us maintain the
security of our Services, prevent crashes, fix bugs,
save your preferences, and assist with
basic site functions.
We also permit third parties and
service providers to use online
tracking technologies on our Services
for analytics and advertising,
including to help manage and display
advertisements, to tailor
advertisements to your interests, or
to send abandoned shopping cart
reminders (depending on your
communication preferences). The third
parties and service providers use
their technology to provide
advertising about products and
services tailored to your interests
which may appear either on our
Services or on other websites.
To the extent these online tracking
technologies are deemed to be a 'sale'/'sharing'
(which includes targeted advertising, as
defined under the applicable laws) under
applicable US state laws, you can opt out
of these online tracking technologies by
submitting a request as described below under
section
'DO UNITED STATES RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?'
Specific information about how we use
such technologies and how you can
refuse certain cookies is set out in
our Cookie Notice:
__________.
6. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short: We keep your information for as
long as necessary to fulfil the purposes outlined in this
privacy notice unless otherwise required
by law.
We will only keep your personal
information for as long as it is
necessary for the purposes set out in
this privacy notice, unless a longer
retention period is required or
permitted by law (such as tax,
accounting, or other legal
requirements).
No purpose in this notice will require
us keeping your personal information for
longer than
2 years.
When we have no ongoing legitimate
business need to process your personal
information, we will either delete or anonymise
such information, 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.
7. HOW DO WE KEEP YOUR
INFORMATION SAFE?
In Short: We aim to protect your personal
information through a system of organisational and technical security measures.
We have implemented appropriate and
reasonable technical and organisational
security measures designed to protect the
security of any personal information we
process. However, despite our safeguards
and efforts to secure your information,
no electronic transmission over the Internet
or information storage technology can be
guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals,
or other
unauthorised
third parties will not be able to defeat
our security and improperly collect, access,
steal, or modify your information. Although
we will do our best to protect your personal
information, transmission of personal information
to and from our Services is at your own
risk. You should only access the Services
within a secure environment.
8. DO WE COLLECT INFORMATION
FROM MINORS?
In Short: We do not knowingly collect
data from or market to children under 18 years of
age.
We do not knowingly collect, solicit
data from, or market to children under
18 years of age, nor do we knowingly
sell such personal information. By
using the Services, you represent that
you are at least 18 or that you are
the parent or guardian of such a minor
and consent to such minor dependent’s
use of the Services. If we learn that
personal information from users less
than 18 years of age has been
collected, we will deactivate the
account and take reasonable measures
to promptly delete such data from our
records. If you become aware of any
data we may have collected from
children under age 18, please contact
us at [email protected].
9. WHAT ARE YOUR PRIVACY
RIGHTS?
In Short: Depending on your state of
residence in the US or in
some
regions, such as
the European Economic Area
(EEA), United Kingdom (UK),
Switzerland, and Canada, you have rights that allow
you greater access to and control
over your personal information. You may review, change, or
terminate your account at any time,
depending on your country, province,
or state of residence.
In some regions (like the EEA, UK, Switzerland, and
Canada), you have certain rights
under applicable data protection laws.
These may include the right (i) to
request access and obtain a copy of
your personal information, (ii) to
request rectification or erasure;
(iii) to restrict the processing of
your personal information; (iv) if
applicable, to data portability; and
(v) not to be subject to automated
decision-making. In certain
circumstances, you may also have the
right to object to the processing of
your personal information. You can
make such a request by contacting us
by using the contact details provided
in the section
'HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?'
below.
We will consider and act upon any
request in accordance with applicable
data protection laws.
Withdrawing your consent:
If we are relying on your consent to process
your personal information,
which may be express and/or implied consent
depending on the applicable law,
you have the right to withdraw your consent
at any time. You can withdraw your consent
at any time by contacting us by using the
contact details provided in the section
'HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?'
below.
However, please note that this will not
affect the lawfulness of the processing
before its withdrawal nor,
when applicable law allows,
will it affect the processing of your personal
information conducted in reliance on lawful
processing grounds other than consent.
Cookies and similar technologies:
Most Web browsers are set to accept cookies
by default. If you prefer, you can usually
choose to set your browser to remove cookies
and to reject cookies. If you choose to
remove cookies or reject cookies, this
could affect certain features or services
of our Services.
For further information, please see
our Cookie Notice:
__________.
If you have questions or comments about
your privacy rights, you may email us at [email protected].
10. CONTROLS FOR DO-NOT-TRACK
FEATURES
Most web browsers and some mobile
operating systems and mobile
applications include a Do-Not-Track ('DNT') feature or setting you can
activate to signal your privacy
preference not to have data about your
online browsing activities monitored
and collected. At this stage, no
uniform technology standard for
recognising
and implementing DNT signals has been
finalised. As such, we do not currently
respond to DNT browser signals or any
other mechanism that automatically
communicates your choice not to be
tracked online. If a standard for
online tracking is adopted that we
must follow in the future, we will
inform you about that practice in a
revised version of this privacy
notice.
California law requires us to let you
know how we respond to web browser DNT
signals. Because there currently is not
an industry or legal standard for recognising
or
honouring DNT signals, we do not respond to
them at this time.
11. DO UNITED STATES
RESIDENTS HAVE SPECIFIC
PRIVACY RIGHTS?
In Short: If you are a resident of
California, Colorado, Connecticut, Delaware,
Florida, Indiana, Iowa, Kentucky, Montana,
New Hampshire, New Jersey, Oregon, Tennessee,
Texas, Utah, or Virginia, you may have the right to
request access to and receive
details about the personal
information we maintain about you
and how we have processed it,
correct inaccuracies, get a copy of,
or delete your personal information.
You may also have the right to
withdraw your consent to our
processing of your personal
information. These rights may be
limited in some circumstances by
applicable law. More information is
provided below.
Categories of Personal Information
We Collect
We have collected the following
categories of personal information in
the past twelve (12) months:
| Category | Examples | Collected |
A. Identifiers | Contact details, such as real
name, alias, postal address,
telephone or mobile contact
number, unique personal
identifier, online identifier,
Internet Protocol address,
email address, and account
name |
YES
|
B. Personal information as
defined in the California
Customer Records statute | Name, contact information,
education, employment,
employment history, and
financial information |
YES
|
C. Protected
classification characteristics
under state or federal law | Gender, age, date of birth,
race and ethnicity, national
origin, marital status, and
other demographic data |
NO
|
D. Commercial
information | Transaction information,
purchase history, financial
details, and payment
information |
NO
|
E. Biometric information | Fingerprints and voiceprints |
NO
|
F. Internet or other
similar network activity | Browsing history, search
history, online behaviour, interest data, and
interactions with our and
other websites, applications,
systems, and advertisements |
NO
|
G. Geolocation data | Device location |
NO
|
H. Audio, electronic,
sensory, or similar
information | Images and audio, video or
call recordings created in
connection with our business
activities |
NO
|
I. Professional or
employment-related information | Business contact details in
order to provide you our
Services at a business level
or job title, work history,
and professional
qualifications if you apply
for a job with us |
NO
|
J. Education Information | Student records and directory
information |
NO
|
K. Inferences drawn from
collected personal information | Inferences drawn from any of
the collected personal
information listed above to
create a profile or summary
about, for example, an
individual’s preferences and
characteristics |
NO
|
| L. Sensitive personal
Information | |
NO
|
We may also collect other personal
information outside of these categories
through instances where you interact
with us in person, online, or by phone
or mail in the context of:
- Receiving help through our customer
support channels;
- Participation in customer surveys or
contests; and
- Facilitation in the delivery of our
Services and to respond to your
inquiries.
We will use and retain the collected
personal information as needed to provide
the Services or for:
Sources of
Personal
Information
How We Use and
Share Personal
Information
Will your
information be
shared with
anyone else?
We may use your
personal
information for
our own business
purposes, such as
for undertaking
internal research
for technological
development and
demonstration.
This is not
considered to be 'selling'
of your personal information.
We have not
disclosed, sold,
or shared any
personal
information to
third parties for
a business or
commercial purpose
in the preceding
twelve (12)
months. We will not sell or
share personal
information in the
future belonging
to website
visitors, users,
and other
consumers.
Your Rights
You have rights
under certain US
state data
protection laws.
However, these
rights are not
absolute, and in
certain cases, we
may decline your
request as permitted
by law. These rights
include:
- Right to know
whether or not we are
processing your personal
data
- Right to
access your personal data
- Right to
correct inaccuracies in
your personal data
- Right to request
the deletion of your
personal data
- Right to obtain a
copy of the personal
data you previously
shared with us
- Right to
non-discrimination
for exercising your rights
- Right to opt out
of the processing of
your personal data if
it is used for targeted
advertising
(or sharing as defined
under California’s privacy
law), the sale of
personal data, or
profiling in
furtherance of
decisions that
produce legal or
similarly
significant effects
('profiling')
Depending upon the
state where you
live, you may also
have the following
rights:
- Right to obtain a
list of the
categories of third
parties to which we
have disclosed
personal data (as
permitted by
applicable law,
including
California's and Delaware's
privacy law)
- Right to obtain a
list of specific
third parties to
which we have
disclosed personal
data (as permitted
by applicable law,
including Oregon’s
privacy law)
- Right to limit use
and disclosure of
sensitive personal
data (as permitted
by applicable law,
including
California’s privacy
law)
- Right to opt out of
the collection of
sensitive data and
personal data
collected through
the operation of a
voice or facial
recognition feature
(as permitted by
applicable law,
including Florida’s
privacy law)
How to Exercise
Your Rights
Under certain US
state data
protection laws, you
can designate an authorised
agent to make a request
on your behalf. We may
deny a request from an
authorised
agent that does not submit
proof that they have
been validly
authorised to act on your
behalf in accordance
with applicable laws.
Request
Verification
Upon receiving your
request, we will
need to verify your
identity to
determine you are
the same person
about whom we have
the information in
our system. We will
only use personal
information provided
in your request to
verify your identity
or authority to make
the request.
However, if we
cannot verify your
identity from the
information already
maintained by us, we
may request that you
provide additional
information for the
purposes of
verifying your
identity and for
security or
fraud-prevention
purposes.
If you submit the
request through an authorised agent, we may
need to collect additional
information to verify
your identity before
processing your request
and the agent will need
to provide a written
and signed permission
from you to submit such
request on your behalf.
Appeals
Under certain US
state data
protection laws, if
we decline to take
action regarding
your request, you
may appeal our
decision by emailing
us at [email protected]. We will
inform you in
writing of any
action taken or not
taken in response to
the appeal,
including a written
explanation of the
reasons for the
decisions. If your
appeal is denied,
you may submit a
complaint to your
state attorney
general.
California 'Shine The
Light' Law
California Civil
Code Section
1798.83, also known
as the 'Shine The
Light'
law, permits our users
who are California residents
to request and obtain
from us, once a year
and free of charge, information
about categories of personal
information (if any)
we disclosed to third
parties for direct marketing
purposes and the names
and addresses of all
third parties with which
we shared personal information
in the immediately preceding
calendar year. If you
are a California resident
and would like to make
such a request, please
submit your request in
writing to us by using
the contact details provided
in the section
'HOW CAN YOU
CONTACT US ABOUT
THIS NOTICE?'
12. DO OTHER
REGIONS HAVE
SPECIFIC PRIVACY
RIGHTS?
In Short: You may
have additional
rights based on
the country you
reside in.
Australia and New Zealand
We collect and
process your
personal information
under the
obligations and
conditions set by Australia's
Privacy Act 1988
and
New Zealand's
Privacy Act 2020 (Privacy Act).
This privacy notice
satisfies the notice
requirements defined
in
both Privacy Acts, in
particular: what
personal information
we collect from you,
from which sources,
for which purposes,
and other recipients
of your personal
information.
If you do not wish
to provide the
personal information
necessary to fulfil their applicable
purpose, it may affect
our ability to provide
our services, in particular:
- offer you the
products or
services that you
want
- respond to or
help with your
requests
Republic of
South Africa
If you are
unsatisfied with
the manner in
which we address
any complaint
with regard to
our processing
of personal
information, you
can contact the
office of the
regulator, the
details of which
are:
13.
DO WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short: Yes, we
will update
this notice
as necessary
to stay
compliant
with
relevant
laws.
We may update
this privacy
notice from
time to time.
The updated
version will
be indicated
by an updated 'Revised' date at
the top of this
privacy notice.
If we make material
changes to this
privacy notice,
we may notify you
either by prominently
posting a notice
of such changes
or by directly
sending you a notification.
We encourage you
to review this
privacy notice
frequently to be
informed of how
we are protecting
your information.
14.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If you have
questions or
comments about
this notice,
you may email us
at
[email protected]
or contact
us by
post at:
Zureli
Limited
4th Floor
Silverstream
House
45 Fitzroy
Street
London W1T 6EB
England
15.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based
on the
applicable
laws of your
country
or state of residence
in the US, you
mayhave the
right to
request
access to
the
personal
information
we collect
from you,
details
about how
we have
processed
it,
correct
inaccuracies,
or delete
your
personal
information.
You may
also have
the right
to withdraw
your
consent to
our
processing
of your
personal
information.
These
rights may
be limited
in some
circumstances
by
applicable
law. To
request to
review,
update, or
delete
your
personal
information,
please
fill
out and
submit
a data
subject
access
request.