TERMS AND PRIVACY POLICY FOR EU CITIZENS
Under the General Data Protection Regulation (GDPR) of the European Union (EU), EU citizens are entitled to certain privacy protections regarding the use of, storing, and processing of your personal information as well as having right to be notified if personal information is stolen, copied or accessed on an unauthorized basis.
The GDPR is a modern privacy rights framework adopted to create better transparency and control over who, how and when your personal data may be used, including the “right to be forgotten”.
This section will explain how Company complies with the GDPR and how your personal data may be collected, stored, and used. We also explain under what circumstances and for what purposes we may use your personal data and also provide instructions on how you can “opt-out” from our using your personal data and also request the removal of your personal data from our systems.
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OUR BUSINESS
Our business is related to providing pet sitting and house sitting services in California, USA. Under the GDPR, if you are an employee of or associated with a business customer, certain information may be considered personal data such as your business email, business mobile number or other similar information from which your personal identitymaybeknown. Itisalsocustomaryinmanyinstancesforbusinessassociatesofbusinessorgovernment customers to furnish their private or personal contact information such as private email address, home telephone number, and similar information. Even if done in the context of a business purpose, this information may be deemed personal data. Therefore, if you believe your business information discloses personal data that you do not wish disclosed, you should not give it to us. You should also ask your employer to change your business contact information an anonymized format, such as changing your email form “my.name@mycompany” to “randomcharacters@mycompany”.
Please be advised that our business has less than 250 employees. Accordingly, we are subject to less stringent recording requirements under GDPR requirements. We are, however, not exempt from other privacy protection and reporting requirements which apply to all businesses equally.
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COLLECTION AND USE OF YOUR PERSONAL DATA
Our ability to use your personal data may come about by the following means:
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By Your Consent. You may expressly give your consent to our using your data for the specific purposes wedetailbelow. Evenifyougiveconsent,however,youcansubsequentlywithdrawyourconsentatany time without retribution.
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By Other Permitted Means. We may collect your personal data under certain other cases whether consent is expressly given as follows:
(a) Contractual obligations. In certain circumstances, we need your personal data to comply with our contractual obligations. This would include information such as your and your employer’s name, address, telephone number, email address, driver’s license, or other document number associated with identity for the purpose of delivery of Services, billing, collection, legal notification, authentication,andcontractenforcement. Forexample,ifyouworkforanemployerwhodesignates you as a point of contact for purposes of contract administration or notice, we will retain that information and use it for such purposes and for other related purposes as is reasonable.
(b) Legal compliance. If the law requires us to, we may need to collect and process your data. This data may include personal identification data, transactional data relating to purchases, and communications data such as IP address, telephone number, and other meta-data. For example, we can pass on details of people involved in fraud or other criminal activity to law enforcement. If you reside outside of the United States or are a non-US citizen, we may collect personal data from you and other third-party sources for purposes of complying with export control, anti-money laundering, and anti-terrorism laws, rules, and regulations.
(c) Legitimate interest. In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom, or interests. For example, we may use your contact information to send information and updates regarding our Services, endorsement of our Services or their use by others, recommendations on optimizing the use of our Services, updates, new properties, offers regarding Services and other education information or information of interest relevant to you.
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HOW WE USE YOUR PERSONAL DATA
We will use your personal data only in connection with furthering our relationship with you, to enhance and protect the security of your information, and to enable your use of our Services.
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We will not sell, rent, lease, or transfer your data to any third-party commercial entity for the purpose of marketing or selling unrelated products or services for our financial gain or economic benefit. We may share basic contact information such as your name and contact information (“Basic Information”) and services information, including technical configuration information, customer compliant information, trouble-shooting information with third party product and solutions providers that work with our products, such as channel partners and sales representatives, product repair and service providers, and operationalization consultants and specialists (“Sales and Service Partners”).
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Security Data Use. We will use your personal data that is Security Data when it is necessary to perform security authentication functions related to purchasing, payment and the use of our products and services. We may link or issue encrypted tokens to your applications or devices to provide increased security and to limit the transmission of your passwords or other sensitive data.
If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below. However, if you choose not to share your personal data with us, or refuse certain contact permissions, Company
might not be able to provide the Services you require.
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HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. We have outlined above the various circumstances, purposes, and time periods when we will hold personal data.
At the end of that retention period, your data will either be deleted completely or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. To summarize:
Ten Years from Transaction date. As described above, you should expect your personal data including any pertinent Relationship Data to be held for ten (10) years from the date of its creation for contract and legal purposes. The same ten-year period would apply to Security Data from the date of its last use or transactional entry.
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WHERE WILL YOUR PERSONAL DATA BE PROCESSED
We will not transfer your personal data to any provider in any jurisdiction unless such provider and jurisdiction meet the requirement under the GDPR.
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YOUR RIGHTS OVER YOUR PERSONAL DATA
Below is an overview of your various rights. You have the right to request:
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Access to the personal data we hold about you, free of charge in most cases.
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The correction of your personal data when incorrect, out of date, or incomplete.
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The deletion of the data we hold about you, in specific circumstances. For example, when you withdraw
consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold
the data has come to an end.
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A computer file in a common format (e.g. CSV or similar) containing the personal data that you have
previously provided to us and the right to have your information transferred to another entity where this
is technically possible.
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Restriction of the use of your personal data, in specific circumstances, generally whilst we are deciding
on an objection you have made.
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That we stop processing your personal data, in specific circumstances. For example, when you have
withdrawn consent, or object for reasons related to your individual circumstances. Please be advised, however, your employer may reasonably object as the customer having direct contract relationship with us, and we reserve the right to notify your employer or organization of such as request and advise them that removal may impair the intended use or enjoyment of our product and services functions.
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That we stop using your personal data for direct marketing (either through specific channels, or all channels).
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That we stop any consent-based processing of your personal data after you withdraw that consent.
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Review by a partner of any decision made based solely on automatic processing of your data (i.e. where
no human has yet reviewed the outcome and criteria for the decision).
You can contact us to request to exercise these rights at any time by completing an online form. If we choose not to adhere to your request we will explain to you the reasons for our refusal.
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YOUR RIGHT TO WITHDRAW CONSENT
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
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RIGHT TO STOP DIRECT MARKETING
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
This right does not include communications and information functions, such as alerts and notices, which are displayed in any application or product interface of ours which is part of the operation of or relates to a normal function of our product. By using our products or services, you are expressly giving your consent for such purposes. If you disagree with that then do not use our products or services.
CHECKING YOUR IDENTITY
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
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HOW TO SEND US NOTICE
You may send us notice of the exercise of your rights, whether to “opt-out” of certain or all marketing channels, to request deletion of your personal data or to correct, receive a copy of your personal data by any of the following means:
Via Email: Send us an email with the subject line “GDPR Request”. Please include the action you are requesting we take, the basis for the action, and any information which can reasonably identify you, and valid means to respond back to you.
Online: When you send us a communication through a form, you may check a box indicating your preference to opt-out of marketing campaigns and contacts.
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COMPLAINTS OR CONCERNS
We are dedicated to adhering to the EU’s privacy laws for our EU customers. If you believe that we are not fulfilling our obligations in accordance with the law, you may file a complaint with the European Data Protection Supervisor (EDPS). We have provided this link for your convenience (note you are linking to an external third- party site unaffiliated with us):
https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en
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RESERVATION OF RIGHTS
We provide this privacy notice to EU citizens in accordance with our understanding of the GDPR and will endeavor to comply with such law on a voluntary basis. We reserve all rights afforded under United States laws and treaties. ThisprivacynoticeisnotacontractualobligationorguaranteetoyouthatmaybeenforcedintheUnited States or any other jurisdiction which does not recognize the GDPR as part of its law. Our contract obligations are limited to those contained in the purchase agreements and end-user license agreements between us and our customers. We, for ourselves and on behalf of directors, officers, employees, advisors, and all other persons affiliated with us reserve all rights regarding personal and subject jurisdictional matters, and the applicability and enforcement of the GDPR with respect to US citizens and non-EU citizens. Neither this privacy notice nor any actions taken to comply with the GDPR shall constitute a waiver of such rights or submission to jurisdictional authority of any court, tribunal, or governmental authority outside of the United States.
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QUESTIONS
If you have any questions about our privacy practices or this Privacy Policy, please contact us.