Effective: May 1, 2018
OUR COMMITMENT TO PRIVACY
COLLECTION OF INFORMATION
We collect information, such as usage statistics, by using cookies, server logs, and similar technologies.
If you elect to use certain features, we also collect information from other sources, such as social media services, invitations, and imported contacts.
Information You Provide to Us
We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, fill out a form, or communicate with us. The types of information that we may collect include your name, username, password, email address, postal address, phone number, payment method data, and any other information that you choose to provide.
Information We Collect Automatically When You Use the Community Platform
When you use our Community Platform, we automatically collect information about you, including:
- Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration, and frequency of your access; Platform pages viewed; and your IP address.
- Location Information: We may collect information about the location of your device each time you use our Platform based on your consent to the collection of this information.
- Information Collected by Cookies and Other Tracking Technologies: We and our service providers collect information using various technologies, including cookies and pixel tags (which are also called clear GIFs, web beacons, or pixels). Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, and track usage of our Platform. Pixel tags are electronic images that may be used in our Platform or emails and that track usage of our Platform and effectiveness of communications.
- Cookies: Most devices and web browsers are set to accept cookies by default. If you prefer, you may be able to remove or reject cookies. You can learn more about how to block cookies by visiting allaboutcookies.org. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Platform.
USE OF INFORMATION
Operating our Platform
We may use information about you for various purposes related to operating our Platform, including the following:
- Provide, maintain, and improve our Platform, including to process transactions, develop new products and services, and manage the performance of our Platform;
- Monitor and analyze trends, usage, and activities in connection with our Platform;
- Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities;
- Protect the rights, property, or safety of others;
- Enforce compliance with our policies;
- Comply with applicable law and government requests;
- Perform accounting and administrative tasks; and Enforce or manage legal claims.
Communicating with You
We may use information about you for various purposes related to communicating with you, including the following:
- Respond to your comments, questions, and requests, and provide customer service;
- Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others;
- Provide news and information that we think will be of interest to you;
- Conduct online surveys;
- Contact you about events on our Platform that are being held near your location, and to otherwise communicate with you; and
- Send you technical notices, updates, security alerts and support, and administrative messages.
Legal Basis for Processing
Our legal basis for collecting and using the information described above will depend on the type of information and the specific context in which we collect it.
We process information about you in order to provide our services in accordance with any Paladin Group Terms of Service. For example, to allow us to send you important service updates. We also process information about you where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Platform).
We may also process information to comply with a legal requirement or to perform a contract.
SHARING OF INFORMATION
Through Our Platform
We share some of the information that we collect by displaying it on our Platform according to your member profile and account settings. We recommend that you check the settings to ensure that you are agreeable with the information that is visible.
With Our Service Providers
We may use service providers in connection with operating and improving the Platform to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, and some aspects of our technical and customer support.
We take measures to ensure that these service providers access, process, and store information about you only for the purposes we authorize, subject to confidentiality obligations, and per applicable privacy and security laws and regulations.
Following the Law and Protecting Paladin Group
We may access, preserve, and disclose information about you to third parties, including the content of messages, if we believe disclosure is in accordance with or required by applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with any Paladin Group Terms of Service; if we believe that your actions are inconsistent with related guidelines and policies; if necessary to protect the rights, property, or safety of Paladin Group websites or Platforms; or if necessary to prevent fraud or abuse of Paladin Group websites or Platforms.
Affiliate Sharing and Merger, Sale, or Other Asset Transfers
If Paladin Group is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.
We may de-identify or aggregate information about you and share it freely so that you can no longer be identified. We may also share information about you with your consent, at your direction, or where we are legally entitled to do so.
Transfer of Information to the United States and Other Countries
We employ technical and organizational measures designed to appropriately protect your information that is under our control and that we process on your behalf from unauthorized access collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. We store all information that you provide to us on secure servers. We train employees regarding our data privacy policies and procedures and permit authorized employees to access information on a need-to-know basis, as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.
Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential.
We retain certain information that we collect from you while you are a member of the Platform, and in certain cases where you have deleted your account, for the following reasons:
- So you can use our Platform;
- To ensure that we do not communicate with you if you have asked us not to;
- To provide you with a refund, if entitled;
- To better understand the traffic to our Platform or websites in order to provide the best possible experience;
- To detect and prevent abuse of our Platform, illegal activities, and breaches of our Terms of Service; and
- To comply with applicable legal, tax, or accounting requirements.
- When we have no ongoing legitimate business need to process your information, we will either delete or anonymize it.
Paladin Group is a data processor and does not fit the definition of a controller. Paladin Group employees and administrators are NOT directly responsible for complying with requirements of applicable EU privacy laws in connection with the information that they obtain.
Revisions to this Policy
We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. You can contact us by sending an email to firstname.lastname@example.org. Rights that you may have, depending on the country in which you live, include:
- Accessing, correcting, updating, or requesting deletion of your information.
- Objecting to the processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.
- Opting out from receiving marketing communications that we send you at any time.
- Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.
- Complaining to a data protection authority about our collection and use of your information.
For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available here.
Under European data protection law, the processor of your information is Outbox Systems, Inc.