Last Modified: 10, 2019
COLLECTION AND USE OF PERSONAL INFORMATION
Personal information is information that can be used to directly or indirectly identify you. Personal information also includes anonymous information that is linked to information that can be used to directly or indirectly identify you. Personal information does not include information that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you. Here is a description of the types of personal information we may collect and how we may use it:
What Personal Information We Collect Depending on the services you use, we collect different kinds of personal information from or about you.
- Information you provide: We may collect some types of personal information you provide voluntarily — such as your name, username, physical address and email address — when you use our services, create an account, approach us at: Privacy@eyeclick.com, participate in an online survey, participate in community discussions or chat rooms, apply for employment, interact with us at in-person events, or otherwise interact with us. With respect to any personal information of your child or a child under your custody or legal guardianship, you hereby represent and warrant that you give your verifiable parental consent to such collection and retention of personal information in compliance with applicable law.
- Information about payments: If you make a purchase, we collect personal information in connection with the purchase. This information includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping, and contact details.
- Information about use of our Services: When you visit our Website or use or services, we may collect information about the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of Internet browser that you use, usage information, diagnostic information, browsing information, session summary information, file attributes (including attributes for photos, videos, music, and documents), and location information from or about the computers, phones, or other devices on which you install or access our products or services. We may gather
some of this information automatically. Where available, our services may use GPS, your IP address, and other technologies to determine a device’s approximate location to allow us to improve our services.
- Information from third parties: We may collect information from third parties, including business partners and marketing agencies. This includes your contact information from marketing partners when we engage in joint marketing or co-branding activities, your IP address or location information from service providers to offer certain products and services relevant to your location.
Legal Basis for Processing
Our collection and processing of personal information is based on the following:
a. The need to carry out the above processing of information, which is in anticipation of entering into commercial engagements or as part of the performance of existing engagements with you, for example for providing you the Goods and items that you ordered through our Website.
b. To the extent that we use the personal information for advertising or promotional activities, including direct mailing and targeted advertising, we will request your specific, freely-given, unbundled, informed and separate consent to such uses.
c. To the extent that we use the personal information to improve this Website, services or for analyzing statistics, the basis for collection of data is our legitimate interest to conduct such improvements and analysis.
How We Use Your Personal Information
Generally speaking, we use personal information to provide the Goods you have ordered and to further improve and develop our different products and services, to communicate with you, to offer you targeted advertisements and services, and to protect us and our users.
EyeClick collects, processes, and determines how to process your personal information as data controller for the following purposes:
- Processing Orders and providing Goods to you: We may use personal information and other contact information, for the purpose of processing your Orders and purchases and delivering the Goods you ordered to you, for example, arranging for shipping and handling, processing your payment details and managing your returns.
- Providing, improving, and developing our Services: We may use personal information to help us provide, improve, and develop our Website, Goods, services, products and advertising. This includes using personal information for purposes such as data analysis, research, and audits. Such processing is based on our legitimate interest in offering you products and services and for business continuity.
- Communicating with you: Subject to your prior express, free and informed consent, we may use personal information to send you marketing communications in relation to EyeClick’s own products and services; communicate with you about your account or transactions; and inform you about our policies and terms. Also subject to your prior express consent, we may share your personal information with third-party partners who may send you marketing communications in relation to their products and services. If you no longer wish to receive email communications for marketing purposes, please approach us at: Privacy@eyeclick.com to opt out. We may use your information
to process and respond to your requests when you approach us at: Privacy@eyeclick.com.
- Offering and measuring targeted advertisements and services: Subject to your prior express consent, we may use personal information to personalize your experience with our Website and services, on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.
- Provide customer service and answer you inquiries: when you submit inquiries or requests with respect to the Website, services, Goods or our products, or when you contact us for such purpose. We will use such information to contact you only for the purposes for which you sent the inquiry.
For any of the uses of your data described above that require your prior express consent, note that you may withdraw your consent by approach us at: Privacy@eyeclick.com.
- Promoting safety and security: We use personal information to help verify accounts and user activity, as well as to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies. Such processing is based on our legitimate interest in helping ensure the safety of our products and services.
As a global company, EyeClick Corporation has a number of corporate affiliates in different jurisdictions. Each of these affiliates collects, processes and determines how to process your personal information as a data controller to help provide you the products and services you request.
COOKIES AND SIMILAR TECHNOLOGIES
DISCLOSURE OF PERSONAL INFORMATION
We make certain personal information available to strategic partners that work with us to provide our services and Goods or help us market to customers. Personal information will only be shared by us with these companies in order to process your Orders and provide you with the Goods or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent.
We share personal information with companies that provide services on our behalf, such as shipping and handling companies; carriers; credit card payment services; website hosting; email services; marketing and other promotions; auditing; payment processing; fulfilling customer orders; data analytics; providing customer services and support; conducting customer research and satisfaction surveys; and other services that assist in our services and selling our Goods and
other products. We will only provide these service providers the information they need to perform the applicable service, and they are prohibited from using that information for any other purpose. These companies are obligated to protect your information and may be located wherever we operate.
Corporate Affiliates and Corporate Business Transactions
Legal Compliance and Security
It may be necessary — by law or as a result of legal process, litigation, or requests from public or governmental authorities within or outside your country of residence — for us to disclose personal information. We may also disclose personal information if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose personal information if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our Terms and Conditions, investigate fraud, or protect our operations or users. We will not sell or otherwise transfer the personally identifiable information you provide to us at our Website to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.
We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date. Depending on where you live, you may have the rights described below. You have the right to access, correct, or delete the personal information that we collect. You are also entitled to object to or restrict, at any time, the further processing of your personal information. You have the right to receive your personal information in a structured and standard format. You may lodge a complaint with the competent data protection authority regarding the processing of your personal information.
To protect the privacy and the security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
You can opt-out of receiving marketing communications by modifying your preferences in the User Account or by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message. Alternatively, you can contact us using the contact details below.
You may approach us at: Privacy@eyeclick.com to exercise your rights. We will respond to your request in a reasonable timeframe, and in any event in less than 30 days.
California Privacy Rights
If you are a California resident, California law permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please approach us at: Privacy@eyeclick.com and include “California Privacy Rights Request” in the first line of the request.
Please approach us at: Privacy@eyeclick.com to close your account in relation to the following uses of your personal information:
- providing, improving, and developing our services;
- communicating with you;
- sharing your personal information with third-party partners for marketing communications;
- offering and measuring targeted advertisements and services;
- provide customer service and answer you inquiries;
- promoting safety and security; or
- providing Goods (for such requests, EyeClick Technologies, Inc. will act on behalf of its local affiliates).
If you close your account, we have no obligation to retain your information, and we may delete any or all of your information without liability. We may retain, however, information related to you if we believe it may be necessary to prevent fraud or future abuse, if required by law, or for legitimate purposes, such as analysis of non-personal information, account recovery, auditing our records, or enforcing our rights and obligations under our agreements.
THIRD-PARTY WEBSITES AND SERVICES
INFORMATION SECURITY, INTEGRITY, AND RETENTION
It is important that you take precautions to protect against unauthorized access to your EyeClick User Account credentials, and computers or other devices. If you feel that the security of your User Account or personal information has been compromised, please immediately approach us at: Privacy@eyeclick.com. EyeClick safeguards the security of the data you send us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your personal information. While we strive to protect your personal information, we cannot ensure the security
We do not knowingly collect, use, or disclose information from children under 16. If we learn that we have collected the personal information of a child under 16 — or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States — we will take steps to delete the information as soon as possible. Please immediately approach us at: Privacy@eyeclick.com if you become aware that a child under 16 has provided us with personal information. If you are a California resident under the age of 18, and you are a registered user of our services, California law permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please approach us at: Privacy@eyeclick.com with specific information about where the content or information is posted and attesting that you posted it. We will then make reasonable, good faith efforts to remove the post from prospective public view, or anonymize it so you cannot be individually identified, to the extent required by applicable law. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
INFORMATION TRANSFERS, STORAGE, AND PROCESSING GLOBALLY
When we share your personal information with our partners, EyeClick-affiliated companies, and service providers, your personal information may be transferred to and/or made accessible from countries out of the European Economic Area (“EU/EEA”) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission we will enter into model contractual clauses as adopted by the European Commission to ensure a sufficient level of protection for your personal information, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our partners or service providers have adopted such internal policies approved by European data protection authorities.
Policy, please refrain from using our products or services and approach us at: Privacy@eyeclick.com to close any account you may have created.