Privacy Policy

Updated: July 27, 2022

Sparta Software Corporation and its affiliates (hereinafter “Sparta,” “we”, “us,” “our,”) provide online and mobile services through various websites, including but not limited to “spartascience.com”, “home.spartascience.com”, “cloud.spartascience.com”, and “spartatrac.com” (hereinafter collectively “the Sparta Sites”), widgets, computer programs and mobile applications hosted by or on behalf of Sparta (collectively, the “Sparta Services”) intended to enhance your use of the performance and monitoring products offered by Sparta (hereinafter collectively the “Sparta Technology”).

Sparta Science respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. Important Information and Who We Are
  2. Third Party Links
  3. The Data We Collect About You
  4. How Is Your Personal Data Collected
  5. How We Use Your Personal Data
  6. Why We Need Your Data
  7. Marketing
  8. Disclosures of Your Personal Data
  9. International Transfers
  10. Data Security
  11. Data Retention
  12. Accessing and Correcting Your Personal Data
  13. Your Right to Delete Your Data
  14. Email Communications From Us
  15. Do Not Track Policy
  16. Do Not Sell My Personal Information
  17. Enforcement and Dispute Resolution
  18. Your California Privacy Rights
  19. Your Canadian Privacy Rights
  20. Your EEA/UK Legal Rights
  21. Glossary
  22. Cookie Use Policy

Important Information and Who We Are

Purpose of this Privacy Policy

Sparta is committed to maintaining the privacy, integrity and security of any personal information about our users. This Privacy Policy (hereinafter the “Policy”) explains how we protect personal information we collect in connection with your use of the Sparta Services, and how we use and in some cases disclose that information. “Personal information” for purposes of this Policy means information that identifies you, such as your name or email address.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

This Policy is subject to the provisions our Terms of Service, which are incorporated by reference.

Controller

SPARTA SOFTWARE CORPORATION is the controller and responsible for your personal data (collectively referred to as “Sparta,” “we”, “us,” “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your EEA/UK legal rights, please contact the data privacy manager using the details set out below.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Sparta Software Corporation

Email address: help@spartascience.com

Postal address: 548 MARKET STREET PMB 89061, SAN FRANCISCO CA 94104

If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you reside within the European Economic Area (EEA), you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. See http://ec.europa.eu for those details. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on February 23, 2022. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party Links

Sparta Sites may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave any of our websites, we encourage you to read the privacy policy of every website you visit.

Third Party Products or Services Offered Through the Sparta Sites

There may be a number of separate products and services such as nutrition, sports and fitness equipment (hereinafter, “Third Party Offers”) that are offered by third parties and advertised by us on the Sparta Sites and through the Sparta Services that may be complementary to your use of the Sparta Technology. If you choose to use these separate products or services, disclose information to the third parties, or grant them permission to collect information about you, then their use of your information is governed by their privacy policies. You should evaluate the practices of these third parties before deciding to accept Third Party Offers.

Sparta is not responsible for privacy practices of any third party. If you click on a link to a third party site, Sparta encourages you to check the privacy policy of that site. Sparta may present links in a format that enables us to keep track of whether these links have been followed and whether any action has been taken on a third party web site. We use this information to improve the quality of the Third Party Offers and customized content on the Sparta Service.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (”de-identified” or “anonymous” data).

The Sparta Technology works in conjunction with a user account (hereinafter “Sparta User Account”) created on any of the Sparta Sites. When you sign up for a Sparta User Account, you are required to provide an email address (which will be used as your login ID) and to create an account password (collectively the “Registration Information”). In order to benefit fully from the Sparta Technology, you can also add additional personal details to your Sparta User Account, such as Health Data (see definition below).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, and birth year.
  • Health Data includes height, weight, and force plate scan data
  • Contact Data includes mailing address, email address, and telephone number.
  • Technical Data includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access Sparta Sites.
  • Profile Data includes your username and password, your preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our website, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We may also collect, use, and share Aggregated Data such as aggregated gender, birth year, height, weight, and usage data (without the inclusion of a User’s name or other identifying information). This may also be statistical or demographic data for any other purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect Financial Information (bank account, payment card details), Transaction Data (payments made by you), and any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). We do not collect any information about criminal convictions and offenses.

Electronic Health Records Disclaimer. At no time shall your Personal Information, including all categories of data collected from you in accordance with this Privacy Policy be deemed to be an electronic health record or an electronic medical record for any purpose, including without limitation for the purpose of compliance with the Health Insurance Portability and Accountability Act of 1996.

Children

We do not knowingly collect any personal information from children under 13. If we discover that a child under the age of 13 has provided us with personally identifying information, we will take steps to delete the information as soon as possible.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you, including through:

    • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
      • create an account on our website;
      • request marketing to be sent to you; or
      • give us feedback or contact us.
    • Automated technologies or interactions. As you interact with Sparta Sites, we will automatically collect your Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

We will also automatically collect your Health Data in case when the website interaction happens with the use of Sparta Technology (force plates, computer programs, mobile applications).

  • Third parties. We will receive personal data about you from various third parties as set out below:
    • Technical and Health Data from the following parties:
      • (Technical Data) analytics providers such as Google based outside the EU; and
      • (Technical Data) search information providers such as Google based outside the EU.
    • Identity, Technical Data, and Health Data from Sparta Technology based outside the EU.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you;
  • Where we need to comply with a legal obligation or enforce the Sparta Terms of Use.
  • Where we Provide you with the Sparta Service;
  • Where we Analyze Sparta Site usage and improve the Sparta Service;
  • Where we Deliver to you or your organization any administrative notices and communications relevant to your use of the Sparta Services and the Sparta Technology;
  • Where we Provide you with updates regarding Sparta Technology;
  • Where we Perform internal market research, project planning, troubleshooting problems, and to detect and protect against error, fraud or other criminal activity;
  • 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.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before collecting sensitive personal data or sending third-party direct marketing communications to you via email. You have the right to withdraw consent to processing your sensitive personal data or to marketing at any time by contacting us.

Why we need your data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Table 1

Purpose/ActivityType of DataLawful basis for processing
To register you as a new customerIdentity
Contact
Performance of a contract with you
To create a Sparta Organization or Organization User Account for youIdentity
Contact
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests
To allow you to use and manage your Sparta Organization and/or Organization User AccountIdentity
Profile
Marketing and Communications
Usage
Performance of a contract with you
Necessary for our legitimate interests
To allow you upload force plate scans to your Sparta Organization accountIdentity
Profile
Health
Usage
Performance of a contract with you
Necessary for our legitimate interests
To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy policy
Asking you to leave a review or take a survey
Identity
Contact
Profile
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise)
Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiencesTechnical
Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, product or service experience, or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of Sparta Sites may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes stated in the table (Why we need your data) above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  • Sparta may disclose your non-personally identifiable aggregated user data, such as aggregated gender, birth year, height, weight, and usage data (without the inclusion of a User’s name or other identifying information) to
    • Organizations approved by Sparta that conduct research into health and wellness;
    • Users of the Sparta Service for purposes of comparison of their personal health, performance and wellness situation relative to the broader community; and
    • Advertisers and other third parties for their marketing and promotional purposes.
  • At times Sparta may make certain personal information available to strategic partners that work with Sparta to provide services to you. In such cases, your account with such third party will continue to be subject to that third party’s privacy policy and your Sparta User Account will continue to be governed by this Policy.
  • We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users or if we are required to do so by any applicable law, rule, regulation, subpoena or other legal process. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third parties offering products or services through Sparta Sites will not be given your personal information without your explicit permission.

Information You Elect to Share With Others

If you use a message board, blog, journal or any other method of posting user-generated content on the Sparta Sites or through the Sparta Services, you should be aware that such information can be read, collected or used by others and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these areas.

Through the Sparta Services, Sparta enables you to share information with others. Many users find this to be an important motivator in achieving their goals. Sparta is dedicated to providing you with full control of your personal data. Sparta generally allows you to set notifications, categories or pieces of data to be private, viewable by friends only, or viewable by the public. We encourage you to consider these privacy settings before sharing information on the Sparta Sites or through the Sparta Services, and to periodically review your privacy settings and adjust them in accordance with your preferences. Anonymous users have no access to the site.

Sparta’s default settings for new users are as follows: Generally, Sparta limits search engine access to the Sparta Sites, and instructs search engines not to index user profile pages. However, search engines may access profile information set to the “public” in your privacy setting.

Your Responsibility for Maintaining the Confidentiality of your Login ID and Password

You are responsible for maintaining the security of your login ID and password. If you believe that your login ID or password have been compromised you should immediately change your password and contact us.

We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of this Policy or the Sparta Terms of Service. If you have a security related concern, please contact us.

International transfers

We are based in the United States. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.

If you are located in the European Economic Area (EEA) or United Kingdom (UK), your personal data may be processed outside of the EEA or UK, including, for example, in the United States, so processing of your personal data will involve a transfer of data outside the EEA or UK.

Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. We use a combination of firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your data and to protect Sparta User Accounts and systems from unauthorized access. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

It is important to understand that these precautions apply only to the Sparta Sites and systems. We exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, reporting, tax, or accounting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting, or other requirements.

  • We keep basic information about our customers (including Contact, Identity, and Health Data) for 5 (five) years after they stop being customers.
  • Details of retention periods for any other aspects of your personal data are available on request by contacting us.
  • In some circumstances you can ask us to delete your data: see accessing and correcting your personal data and your EEA/UK legal rights below for further information.
  • In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Accessing and correcting your personal data

You can access, review, and change your personal data by logging in the website and visiting your account settings page.

You may also send us an email at help@spartascience.com to request access to, correct, or delete any personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

Your Right to Delete Your Data

If you would like to cancel your Sparta User Account you may do so by emailing services@spartascience.com.

When you request cancellation of your account, your personally identifiable information will be deleted, including but not limited your email address, name, and photo(s). Archival copies of your account information that exist within our back-up system will be deleted in accordance with our Data retention schedule.

Following cancellation or termination of your account, Sparta may continue to utilize personally de-identified and anonymized historical data associated with your use of the Sparta Services and the Sparta Technology.

Email Communications From Us

We may provide our registered customers with weekly summaries of their Sparta User Account data and email alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails promoting Sparta or third-party goods or services.

Sparta subscribers have the ability to opt-out of receiving our summaries and promotional emails and to terminate their newsletter subscriptions by following the instructions provided in such emails.

Opting out in this manner will not end transmission of service-related emails, such as email alerts.

Do Not Track policy

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information we collect and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information, visit www.allaboutdnt.com.

Do Not Sell My Personal Information

Sparta Science aims to comply with the U.S. and international legislations that protect privacy and confidentiality of your personal information.
 
We do not sell your personal information to any third parties. All legitimate cases of disclosure of your personal information while using Sparta Science services or platforms are listed under “Disclosures of your personal data” section of this Privacy Policy.

Enforcement and Dispute Resolution

If you have any questions, complaints or disputes regarding the manner in which Sparta handles or protects your personal information, please contact us. Sparta will investigate and attempt to resolve complaints and disputes in a reasonable time and in a manner that complies with the principles described in this Policy.

With respect to any complaints related to this Policy that cannot be resolved through our internal process, you agree to participate in the dispute resolution procedures set forth by the American Arbitration Association. In the event that we, or the appointed arbitrator(s) conclude that we did not comply with thus Privacy Policy, we will take appropriate steps to address any adverse effects and assure our future compliance. Sparta is headquartered in California. The laws of the State of California will govern this Policy, as well as any claim that might arise between you and us, without regard to conflict of law provisions. You agree that jurisdiction for any arbitration or legal action will be only in the State of California, with venue in the County of San Mateo. You agree to submit to the personal jurisdiction of the courts located in San Mateo County, California for the purpose of litigating all such claims.

Your California privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal data.

 

  1. California’s “Shine the Light” law (Civil Code Section 1798.83) permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the name and addresses of all third parties with which we shared personal data in the immediately preceding calendar year. If you are a California resident and would like to make this request, please submit your request in writing to us by email at help@spartascience.com.
  2. The California Consumer Privacy Act (CCPA) provides you with rights regarding how your data or personal information is treated. Under the legislation, California residents can choose to opt out of the “sale” of their personal information to third parties. Based on the CCPA definition, “sale” refers to data collection for the purpose of creating advertising and other communications.

As provided in “Do Not Sell My Personal Information” section of this Privacy Policy, Sparta Science does not sell your personal information to any third parties, so, for the purpose of this Privacy Policy all California residents are considered automatically “opted out” of the sale of their personal information in relation to Sparta Services.

Your Canadian privacy rights

We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.

We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.

Residents of Canada are notified that the personal data they provide to us is stored in our databases outside of Canada, including in the United States, and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.

  • You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions.
  • You have the right to complain about our personal data handling practices.
  • If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us at help@spartascience.com. You may visit www.priv.gc.ca for more information about your privacy rights.

Your EEA/UK legal rights

If you reside in the EEA or UK, under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. 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.
  7. 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 products or 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 the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

  • Compliance with Laws. We may disclose your information where we are legally required to do so to comply with applicable law, government requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to that information to do that work. Examples include: information processing, order fulfillment, product delivery, customer data management, customer research, payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the website, which will enable them to collect data about how you interact with the website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use the website (you can read more about how Google uses your personal data here). You can also opt-out of Google Analytics here.

Cookie Use Policy

Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all our other cookie uses.

Types of Cookies We Use

We may use the following types of cookies:

  • Strictly necessary cookies. Our website requires the use of these cookies to properly operate or provide necessary functions relating to the services you request. They include, for example, cookies enabling you to securely log into our website or make a purchase.
  • Analytical/performance cookies. These cookies allow us and our third-party service providers to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve how our website works by, for example, ensuring that users can easily find what they need on our website. These cookies generate aggregate statistics that are not associated with an individualized profile.
  • Functionality cookies. These cookies enable helpful but non-essential website functions that improve your website experience. By recognizing you when you return to our website, they may, for example, allow us to personalize our content for you, greet you by name, or remember your preferences (for example, your choice of language or region). These cookies may enable visitor identification across websites and over time.
  • Third-party cookies. Our website may contain helpful but non-essential features or plug-ins enabling third-party services that use cookies, such as web traffic analysis services. These cookies may enable visitor identification across websites and over time. We do not control the third party’s use of those cookies. Please review each party’s cookie disclosure before consenting to this use category.

This Privacy Policy describes our practices for any personal data that our first-party cookies collect, store, or use.

Except for strictly necessary cookies, all first-party cookies set by this site will expire no later than two years after your last website visit. Third-party cookie expiration periods are set by their respective owners.

Cross-Border Data Transfers

The cookies we use may process, store, or transfer personal data in and to a country outside your own, with privacy laws that provide different, possibly lower, protections. You consent to this transfer, storing, or processing when you consent to our cookie use. We are based in the United States of America. Please review the third-party cookie provider’s policy to learn more about its location.

Your Cookie Choices

Most web browsers allow you to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation.

Changes to Our Cookie Uses

We will post any changes to the way we use cookies on this page and indicate on our website that we updated this cookie notice. If the changes materially alter how we use cookies, we will post a notice on our website and request your consent for the materially different use. Please check back frequently to see any updates or changes to our cookie use notice.

Contact Information

Please submit any questions, comments, or requests regarding this cookie use notice using the process described in this Privacy Policy.