Therefore, we are constantly reviewing our data processing activities and revising our policies in accordance with the applicable legislation in our present markets.
1. Data Processing Principles
a. Information Automatically Collected.When you access our Websites, we and our possible third party partners automatically record information from your device and its software, such as your IP address, browser type, Internet service provider, platform type, the site from which you came and the site to which you are going when you leave our website, date and time stamp and one or more cookies that may uniquely identify your browser or your account. When you access our Services using a mobile device, we may also receive or collect identification numbers associated with your device (such as a unique device ID, IDFA, Google AdID), device type, model and manufacturer, mobile device operating system brand and model, phone number, email address, and other apps that you have downloaded (“Technical Data”).
b. Location Data.We do not currently collect your precise geolocation or any latitude or longitude coordinates for you. Some of the information we collect, for example an IP address, can sometimes be used to approximate a device’s location. In some cases, we assign the latitude and longitude of the centre of a city or state on record for you to your profile as a way to improve our analytics and offer best matches for you. This is a general latitude and longitude and does not correspond to your real time or historical location specifically.
c. Information Provided by Others. We may link or combine the personal data we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
d. Anonymization.We may anonymize and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymized information for our business purposes including testing our IT systems, research, data analysis, improving our services and developing new products and features. We may also share such anonymized information with others.
Where you do not provide the personal data, we may not be able to provide you the related services; as it may depend on this information
2. How & What Personal Information We Collect and How We Use:
Personal Information We Collect: We only collect and process the following categories of data about companies and business professionals;
- Full Name
- Business Email Address
- Job Title
- Business Phone Numbers (general and direct)
- Business Office Address
- Public Social Link
How and Where We Collect:
- Public Information either publicized by you or by a 3rd party that you have authorized
- Directly and indirectly from user activity on our Website
How and Why We Use:
- We provide accurate business data to our customer to promote their goods and services using direct marketing to the right people (decision makers, influencers, champions etc.);
- Promoting your business in the web searches,
- Enabling you to interact with features or tools on our platform such as live chat;
- Providing you our existing and new services,
- Improving your user experience and our features;
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing prior notice.
The main reason we use your information is to deliver what we offer and constantly improve our services. Additionally, we use your information to help keep you safe and to provide you with advertising that may be of interest to you.
Besides, in line with the aforementioned, we may also use your personal data in the following circumstances:
- Where you have given consent for us to use your personal data, for the stated purposes like; marketing, sales and any sort of informative reasons
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligations.
When the public area of the website is used, the user’s automatically anonymized IP address is saved. As a result of the anonymization, it is impossible to identify the anonymized user and tracking their movement on the website does not allow for any conclusions to be drawn about a specific user.
3. Withdrawing your Consent or Request of Deletion
For GDPR; You may withdraw your consent fully or partially at any time by contacting us from email@example.com from any form on our Website.
For CCPA; You can request the deletion of your personal information by sending an email to firstname.lastname@example.org.
4. Marketing Purposes and Newsletter
From time to time we may contact you with relevant information about our services and products. Most messages we send will be by email. For some messages, we may use personal data we collect about you to help us determine the most relevant information to share with you.
We only contact you once you will provide us your name-surname and e-mail address, which will be deemed as explicit consent to subscribe to our Newsletter.
We use the double opt-in process for our newsletter registration. This means that after your registration we send an email to the email address specified by you; in this email we request your confirmation that you desire to be sent the newsletter. If you do not confirm your registration within 24 hours your data is automatically deleted. Furthermore, we also save your used IP addresses and the times of your registration and confirmation. The purpose of this process is to verify your registration and to possibly explain any mis-usage of your personal data.
If you do not want to receive Newsletters and other messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails or sending an e-mail to us.
5. Disclosure of Your Information to Other Third Parties only if necessary
We may have to share your personal data with the parties in the needed situations as set out below;
- Disclosure to Protect Abuse Victims. We reserve the right, but have no obligation, to disclose any information that you submit to the Websites, if in our sole opinion, we suspect or have reason to suspect, that the information involves a party who may be the victim of abuse in any form. Abuse may include, without limitation, elder abuse, child abuse, spousal abuse, neglect, or domestic violence. Information may be disclosed to authorities that we, in our sole discretion, deem appropriate to handle such disclosure. Appropriate authorities may include, without limitation, law enforcement agencies, child protection agencies, or court officials. You hereby acknowledge and agree that we are permitted to make such disclosure.
- Technology Services Providers, including infrastructure partners (such as AWS), customer support service providers, analytics service providers, cybersecurity partners, fraud analytics companies, payment providers, chargeback representation services and similar partners.
- Advertising networks and technology companies that measure advertising performance and attribution.
- Third parties, including consultants, who we engage to provide services on our behalf or to jointly provide services to you, including but not limited to contests and sweepstakes, marketing outreach and analytics, customer support, safety checks, and payment services (such as Cyber Source).
- To, in our discretion, (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Service, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of the Company, its employees or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
- In connection with any company transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings; and
- We require all third parties to respect the security and privacy of your personal data and to treat it in accordance with the law. However, we are not responsible for those third parties
6. International Transfers The personal data we collect may be transferred to, and processed and stored in, countries outside of your local jurisdiction. If you are located in the European Union ("EU"), your personal data may be processed outside of the EU, including, for example, in US or in Turkey; these international transfers of your personal data are made:
- to a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission; or
- pursuant to appropriate safeguards, such as the Standard Contractual Clauses and Corporate Binding Rules, approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission
7. Data Security
We have extensive security measures in place to protect the loss, misuse and alteration of the information stored in our database. These measures include the use of Secure Socket Layer (SSL) and administrative access to site data as well as other proprietary security measures which are applied to all repositories and transfers of user information. We will exercise reasonable care in providing secure transmission of information between your computer and our servers, but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or warrant the security of any information transmitted to us over the Internet and hence accept no liability for any unintentional disclosure.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (as set out above), including for the purpose of satisfying and legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. Your Rights under GDPR and under CCPA
You may have certain rights under GDPR in relation to your personal data. You have the rights to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the personal data; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need the personal data for the purposes set out above, but we are required by you for the establishment, exercise or defense of legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain features of the services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights, you can contact us from our Websites.
Your Rights Under CCPA;
The CCPA provides California residents the following specific rights regarding processing their personal information;
Access to Specific Information and Data Portability Rights
As a Californian resident; you have the right to request the following;
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected
- Our business or commercial purpose for collecting or selling that personal information,
- The categories of third parties with whom we share that personal information,
- The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights:
You have the right to request us to delete any of your personal data that we process have with some exceptions.
Once we receive your valid request, we will delete (and ask from our service providers and customers to delete as well) your personal information from our systems, unless an exception applies.
We may resist to delete your personal data in the following cases though;
1.Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer. 2.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 3.Debug products to identify and repair errors that impair existing intended functionality. 4.Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 5.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). 6.Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if a consumer previously provided informed consent. 7.Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us. 8.Comply with a legal obligation. 9.Make other internal and lawful uses of that information that are compatible with the context in which a consumer provided it.
Right to Opt-Out of Sale or Sharing of Personal Information:
According to CCPA, you have the following rights to exercise anytime you wish and therefore we pledge to comply with the following accordingly;
(a) to direct a business that sells or shares personal information about the consumer to third parties not to sell or share the consumer’s personal information. This right may be referred to as the right to opt-out of sale or sharing. (b) A business that sells consumers’ personal information to, or shares it with, third parties shall provide notice to consumers, pursuant to subdivision (a) of Section 1798.135, that this information may be sold or shared and that consumers have the “right to opt-out” of the sale or sharing of their personal information. (c) Notwithstanding subdivision (a), a business shall not sell or share the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers at least 13 years of age and less than 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale or sharing of the consumer’s personal information. A business that willfully disregards the consumer’s age shall be deemed to have had actual knowledge of the consumer’s age. (d) A business that has received direction from a consumer not to sell or share the consumer’s personal information or, in the case of a minor consumer’s personal information has not received consent to sell or share the minor consumer’s personal information, shall be prohibited, pursuant to paragraph (4) of subdivision (c) of Section 1798.135, from selling or sharing the consumer’s personal information after its receipt of the consumer’s direction, unless the consumer subsequently provides consent, for the sale or sharing of the consumer’s personal information.
10. Links to Third Party Sites
The Website may, from time to time, contain links to and from third party services. If you follow a link to any of these services, please note that these services have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those services.
11. Our Policy Towards Children
The Website is not directed at persons under 18 and we do not knowingly collect personal data from persons under 18 or from any change that can be deemed as child in your jurisdiction.
12. Changes to This Policy