Last Revised: June 26, 2019
1. Types Of Data We Collect
1.1 Information You Provide
We collect personal data you provide to us. When you register for an account on our Services, we collect the name and email address you enter. We also collect information that you voluntarily submit to us, such as your child’s name, age, birthdate, gender, and profile photo.
In addition, if you contact us for customer support or provide us with feedback, we will collect the data included in the communication. Please contact us at firstname.lastname@example.org if you have questions about the information we collect.
If you participate in a contest, sweepstakes or other promotion, we will collect any data you provide in connection with that promotion. We may also obtain information from other sources and combine that with information we collect on our Services.
1.2 Information Automatically Collected Via Technology
When you use our Services, some information is automatically collected. For example, when you use our Services, we collect some specific device information, such as: device operating system, Internet Protocol (“IP”) address, access times, browser type and language, and device identifier numbers.
We also collect information about your usage and activity throughout our electronic portfolio. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
2. Use Of Your Data
We use personal data collected through our Site, App, and Services for purposes described in this Policy or disclosed to you on our Site, or in connection with our Services. We do use your information to: (i) operate and improve our Services, App, and Sites; (ii) understand you and your preferences to enhance your experience and enjoyment using our Site, App, and Services; (iii) respond to your comments and questions and provide customer support; (iv) to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages; (v) communicate with you about new contests, promotions, rewards, upcoming events, and other news about Services offered by Company and our selected partners; and (vi) link or combine it with other personal data we get from third parties, to help understand your needs and provide you with better service.
From your personal data, we may also create anonymous and de-identified data records so that we may better understand usage of our Services and improve our offering. Company reserves the right to use and disclose anonymous and de- identified data records to third parties at its discretion.
To reiterate, we do not sell your personally identifiable data.
3. Payment Data
If you sign up for our Paid Services, or make other purchases through the Service, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work.
We also collect certain details of your transaction history which are necessary to provide the Paid Services. In addition, the payment processors generally provide us with information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments if you authorize automatic renewals, and your card’s type, expiration date, and certain digits of your card number.
4. Sharing Of Personal Data
We may also share aggregated or de-identified information in our sole discretion.
If you are a California resident, California law permits such users to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those third parties. See the “Contact Information” section for where to send such requests. We do not share personal data with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your personal data to third parties for their direct marketing purposes by withholding consent.
5. Your Right To Withdraw Consent To Processing
Where you have provided your consent to the processing of your personal data by the Company you may withdraw your consent at any time by sending a communication to the Company specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal data, in particular where (i) you contest the accuracy of your personal data; (ii) the processing is unlawful and you oppose the erasure of your personal data; (iii) we no longer need your personal data for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether the legitimate grounds of the Company override your own.
6. Your Choices Regarding Your Personal Data
We allow you to choose which forms of communication you receive from us, how you manage your public information, and how you set your sharing preferences. You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out of receiving promotional emails, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.
We also provide European Union data rights as outlined in Sections 7. And 8. Right below:
7. Your Personal Data Rights
You have the following rights with respect to your personal data where and to the extent they apply to your particular processing:
- The right to request a copy of your personal data which the Company holds about you;
- The right to request that the Company corrects any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for the Company to retain such data;
- The right to withdraw your consent to the processing of your personal data at any time;
- The right to request that the Company provide you with your personal data and where possible, to transmit that data directly to another data controller (where applicable);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing; and
- The right to lodge a complaint with a European Union Data Protection or Supervisory Authority.
8. Exercise Of Your Rights With Regard To Eturi
9. Storage and Transfer of Your Personal Data
The data that we collect from you will be processed and stored at a destination located in the United States.
We transfer data to destinations outside the European Union as a necessary part of the performance of the Services, or with your consent, as applicable.
10. Notice To Previous Child Users Of OurPact Services Who Have Reached The Age Of Digital Majority in Your Jurisdiction
If you are a previous user of OurPact Services that has now reached the age digital majority, the primary account holder may contact us via email@example.com to have personal data that could be used to personally identify you, such as your name, age, birthdate, and profile photo removed from OurPact’s system. Descriptions of such personal data is provided in the “Information You Provide” section.
11. Security Of Your Personal data
The Company is committed to protecting the security of your personal data. We use a variety of industry-standard security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. While Company uses reasonable efforts to protect your personal data, no security measure is completely secure, and we cannot guarantee the security of your information.
12. Retention of your Personal Data
13. Contact Information
15. Complaints To Supervisory Authorities
If you consider that our processing of your personal data infringes European Union data protection laws, in particular if you are an EU resident, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement. For example, in the United Kingdom this is the Information Commissioner’s Office, and in Ireland this is the Data Protection Commissioner.