Last updated January 10, 2020
Personal information you disclose to us In short, we collect personal information that you provide to us such as name address, contact information, passwords and security data and payment information We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Credentials We collect passwords, password hints, and similar security information used for authentication and account access.
Information automatically collected In short, some information – such as IP address and or browser and device characteristics – is collected automatically when you visit
1 OUR SERVICES
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
2 HOW DO WE USE YOUR INFORMATION
In Short,We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and or your consent. We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive: To facilitate account creation and logon process If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. To send you marketing and promotional communications We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the " WHAT ARE YOUR PRIVACY RIGHTS " below). Fulfill and manage your orders We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
Deliver targeted advertising to you We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. Administer prize draws and competitions We may use your information to administer prize draws and competitions when you elect to participate in competitions. Request Feedback We may use your information to request feedback and to contact you about your use of our Services. To protect our Services We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention). To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
To respond to legal requests and prevent harm If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order. To deliver services to the user We may use your information to provide you with the requested service. For other Business Purposes We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
3 WILL YOUR INFORMATION BE SHARED WITH ANYONE
In Short,We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share data based on the following legal basis: Consent,We may process your data if you have given us specific consent to use your personal information in a specific purpose. Legitimate Interests,We may process your data when it is reasonably necessary to achieve our legitimate business interests. Performance of a Contract,Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract. Legal Obligations,We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental 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,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. More specifically, we may need to process your data or share your personal information in the following situations: 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 such information to do that work. Examples include: 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 Services, which will enable them to collect data about how you interact with the Services 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. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. Business Transfers We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4 WHO WILL YOUR INFORMATION BE SHARED WITH
In Short,We only share information with the following third parties. We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
Affiliate Marketing Programs
CJ Affiliate Program
Web and Mobile Analytics
6 HOW LONG DO WE KEEP YOUR INFORMATION
7 HOW DO WE KEEP YOUR INFORMATION SAFE
In Short,We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.
8 DO WE COLLECT INFORMATION FROM MINORS
In Short,We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
9 WHAT ARE YOUR PRIVACY RIGHTS
In Short,In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information You may review, change, or terminate your account at any time. In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal. If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.htm.
If you would at any time like to review or change the information in your account or terminate your account, you can:
■ Log into your account settings and update your user account.
Opting out of email marketing,You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:
■ Access your account settings and update preferences.
10 DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Five Pawns LLC believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Five Pawns LLC becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Five Pawns LLC will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
11 CONTROLS FOR DO NOT TRACK FEATURES
12 DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
In Short,Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the “Shine The Light” law, 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 names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
13 DO WE MAKE UPDATES TO THIS POLICY
14 HOW CAN YOU CONTACT US ABOUT THIS POLICY
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
Five Pawns LLC
18092 Sky Park Circle
Irvine, CA 92614
HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries you may have the right to request access to the personal data we collect from you, change that information or delete in some circumstances. To request to review, update or delete your personal information please submit a request form by clicking here. We will respond to your request within 30 days