Last updated: May 8, 2020.
OWNER AND DATA CONTROLLER
Subscriptionado (“us”, “we”, or “our”) operates https://www.subscriptionado.com (the “Site”).
Contact email: admin@subscriptionado.com
We are committed to protecting and respecting your privacy.
This Site collects some personal data from its users.
This Privacy Policy informs you of our views, practices and policies regarding the collection, use and disclosure of personal data we receive from users of the Site.
By submitting personal data to us, you agree to us using your personal data as follows.
INFORMATION COLLECTION, BUSINESS PURPOSE AND USE
While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to name, email address, cookies, usage data, password.
We may use your personal information to
• send you our newsletters from time to time
• manage contacts and send messages
• ensure that content from our site is presented in the most effective manner for you and for your computer
• provide you with information, products or services that you request from us which may be of interest to you
• carry out our obligations arising from any contracts entered into between you and us
• interact with external social networks and platforms (e.g. social media widgets and share bars)
• allow registration and authentication (e.g. affiliate portals and membership areas)
• allow access to third party services’ accounts
• monitor infrastructure
• manage hosting and backend infrastructure
• interact with live chat platforms
• carry out remarketing and behavioural targeting (including display ads)
• display content from external platforms
• carry out commercial affiliation (e.g. display ads)
• interact with support and feedback platforms
• manage user database
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s and GDPR’s scope
In particular, we have collected the following categories of personal information from our users within the last twelve (12) months:
| Category | Examples | Collected |
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listedin the CaliforniaCustomerRecords statute(Cal. Civ. Code §1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protectedclassificationcharacteristicsunder Californiaor federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO |
| D. Commercialinformation. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometricinformation. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocationdata. | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional oremployment-relatedinformation. | Current or past job history or performance evaluations. | NO |
| J. Non-publiceducationinformation (per the FamilyEducationalRights andPrivacy Act (20U.S.C. Section1232g, 34 C.F.R.Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferencesdrawn from otherpersonalinformation. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you submit or transactions related to products and services you purchase.
- Indirectly from you. For example, from your browser while visiting our Site.
- From third parties. For example, from our business partners or service providers.
We do not intentionally collect or use the personal information of minors under sixteen (16) years of age or sell it with or without affirmative authorization.
In addition to the above, we may collect log data and use cookies.
Log Data
Like many site operators, we collect information that your browser sends whenever you visit our Site.
This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this data.
Cookies
Cookies are text files with a small amount of data, which may include an anonymous unique identifier.
Cookies are sent to your browser from a web site and stored on your computer’s or tablet device’s or mobile device’s part of the hard drive specifically designated for cookies.
It is standard practice to use cookies to make your experience better when using a website.
Like many sites, we use “cookies” to recognize, collect, and/or track information about, and relevant to, your usage of the Site.
Please refer to our Cookie Policy (https://subscriptionado.com/cookie-policy/) for information on what cookies we use, for what purposes we use cookies, and how to control cookies.
Upon your first visit to the Site (and periodically after that), we will request your consent to our use of cookies, except for those strictly necessary.
DATA STORAGE
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
LAWFUL BASIS OF PROCESSING PERSONAL DATA UNDER THE GDPR
We may process personal data relating to users if one of the following applies:
• users have given their consent for one or more specific purposes;
• provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
DATA RETENTION
We process and store your personal data for as long as required by the purpose they have been collected for.
Therefore:
• personal data collected for purposes related to the performance of a contract between us and the user will be retained until such contract has been fully performed;
• personal data collected for the purposes of our legitimate interests will be retained as long as needed to fulfill such purposes;
· we may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn;
· we may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, personal data will be deleted and some of your rights (i.e. the right to access, the right to erasure, the right to rectification and the right to data portability) cannot be enforced after expiration of the retention period. You may find specific information regarding your rights within the relevant section of this Privacy Policy or by contacting us at admin@subscriptionado.com.
THIRD-PARTY DISCLOSURE
We do not sell, trade, or otherwise transfer to outside parties your personal information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:
- Professional service providers.
- Third parties whose services you purchase through our Site.
- Social Media Networks.
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Advertising
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
- Google AdSense & DoubleClick Cookie
Google, as a third party vendor, uses cookies to serve ads on our Service. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet.
You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
YOUR RIGHTS UNDER THE GDPR
Users based in the European Union have the right to do the following:
• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.
• Object to processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.
• Access their data. Users have the right to learn if data is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, we will not process their data for any purpose other than storing it.
• Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from us.
• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any undue delay.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection supervisory authority.
You can exercise your right to prevent such processing by contacting us at admin@subscriptionado.com.
These requests can be exercised free of charge and will be addressed by us as soon as possible and always within thirty (30) days.
YOUR RIGHTS UNDER THE CCPA
Users who reside in California have the right to request any of the following
- disclosure of the categories and specific pieces of personal information we have collected
- deletion of personal information we have collected from you
- disclosure of the categories of personal information we have collected, the categories of sources from which we collected it, the business or commercial purpose for collecting or selling it, the categories of third parties with whom we share it, and the specific pieces of personal information we have collected
- disclosure of the categories of personal information we collected or sold and the categories of third parties to whom it was sold
You have the right not to receive discriminatory treatment for the exercise of these privacy rights.
Requests can be submitted by you or someone legally authorized to act on your behalf by email to admin@subscriptionado.com.
These requests can be exercised free of charge and will be addressed by us as soon as possible and always within forty-five (45) days.
YOUR RIGHT TO OPT OUT OF THE SALE OF PERSONAL INFORMATION
Under the CCPA, “sell,” “selling,” “sale,” or “sold,” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
As per the CCPA definition, selling personal information includes disclosing information to a third party by using analytics tools, running ads or having social media pixels and plugins installed.
Users who reside in California have the right to opt out of the sale of personal information.
Requests to exercise your right to opt out can be submitted by you or someone legally authorized to act on your behalf by email to admin@subscriptionado.com.
NON DISCRIMINATION AND NOTICE OF FINANCIAL INCENTIVES
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.
Any financial incentive we offer will reasonably relate to the value of your personal information and will describe the material terms of the financial incentive program. Participation in any financial incentive program we offer requires your prior consent to opt in, which you may revoke at any time.
We do not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
SECURITY
The security of your personal information is important to us.
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Site as safe as possible.
We use regular Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
CalOPPA (CALIFORNIA ONLINE PRIVACY PROTECTION ACT)
We agree to users visiting our Site anonymously.
Do not track signals
Pursuant to the California Online Privacy Protection Act (CalOPPA), we hereby disclose that we do not currently honor “do not track” signals issued by browsers or other third-party sources.
COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)
For the collection of personal information from children under the age of thirteen (13) years old, we comply with the Children’s Online Privacy Protection Act (COPPA).
The Site is intended for individuals who are eighteen (18) years of age or older.
By visiting and using the Site, you represent and warrant that you are of legal age and meet all of the foregoing eligibility requirements.
The Site is not intended for children under thirteen (13) years of age.
We do not specifically market to children under thirteen (13) years of age. We do not knowingly collect personal information from children under thirteen (13) years of age. We do not knowingly collect personal information from children under thirteen (13).
If you are under thirteen (13) years of age, please do not use the Site or provide any information on the Site, including your name, screen name, username, address, telephone number, email address, and payment details.
If we learn we have collected or received personal information from a child under thirteen (13) years of age without verification of consent from a parent or guardian, the personal information collected or received shall be deleted with no delay.
If you believe we might have any information concerning a child under thirteen (13) years of age, please contact us at admin@subscriptionado.com and we will endeavour to delete such information with no delay.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is effective as of May 8, 2020, and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of our Site after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
We will update our Privacy Policy at least once every twelve (12) months.
CONTACT US
If you have any questions or concerns about this Privacy Policy, please contact us by email to admin@subscriptionado.com.
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