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Effective URL: https://sender.team/PrivacyPolicy.html
Submission: On March 25 via api from PT — Scanned from PT
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* Home
* Legal
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PRIVACY POLICY
CONTENTS
A. A. This Policy
B. B. Collection of Personal Data
C. C. Creation of Personal Data
D. D. Categories of Personal Data we may Process
E. E. Lawful basis for Processing Personal Data
F. F. Sensitive Personal Data
G. G. Purposes for which we may Process your Personal Data
H. H. Disclosure of Personal Data to third parties
I. I. International transfer of Personal Data
J. J. Data security
K. K. Data accuracy
L. L. Data minimisation
M. M. Data retention
N. N. Your legal rights
O. O. Cookies and similar technologies (Cookie Policy)
P. P. Terms of Use
Q. Q. Direct marketing
R. R. Contact details
S. S. Definitions
T. T. Vietnam data privacy law (PDPD)
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(A) THIS POLICY
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* Summary – This Policy
* This Policy explains how we may Process your Personal Data. This Policy may
be amended or updated from time to time, so please check it regularly for
updates.
This Policy is issued by j2 Global Canada, Inc.,on behalf of itself, its
subsidiaries and its affiliates (including any entity lawfully trading under the
Campaigner or SMTP brand) (together,“Company”,“we”, “us” and “our”) and is
addressed to individuals outside our organisation with whom we interact,
including customers, visitors to our Sites, users of our Apps, and other users
of our services (together, “you”). Defined terms used in this Policy are
explained in Section (S) below.
For the purposes of this Policy, Companyis the Controller. This Policy covers
the information practices relating to Company websites for the Campaigner and
SMTP brand and Campaigner and SMTP services ("Services") offered now or in the
future. Contact details are provided in Section (R) below.
This Policy may be amended or updated from time to time to reflect changes in
our practices with respect to the Processing of Personal Data, or changes in
applicable law. We encourage you to read this Policy carefully, and to regularly
check this page to review any changes we might make in accordance with the terms
of this Policy.
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(B) COLLECTION OF PERSONAL DATA
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* Summary – Collection of Personal Data
* We may collect or obtain Personal Data about you: directly from you (e.g.,
where you contact us); in the course of our relationship with you (e.g., if
you make a purchase); when you make your Personal Data public (e.g., if you
make a public post about us on social media); when you download, install, or
use any of our Apps; when you visit our Sites; when you register to use any
of our Sites, Apps, or services; or when you interact with any third party
content or advertising on a Site or in an App. We may also receive Personal
Data about you from third parties (e.g., law enforcement authorities).
Collection of Personal Data: We may collect Personal Data about you from the
following sources:
* Data you provide: We may obtain your Personal Data when you provide it to us
(e.g., where you contact us viaemail or telephone, or by any other means, or
when you provide us with your business card).
* Relationship data: We may collect or obtain your Personal Data in the
ordinary course of our relationship with you (e.g., if you purchase a service
from us).
* Data you make public: We may collect or obtain your Personal Data that you
manifestly choose to make public, including viasocial media (e.g., we may
collect information from your social media profile(s), if you make a public
post about us).
* App data: We may collect or obtain your Personal Data when you download or
use any of our Apps.
* Site data: We may collect or obtain your Personal Data when you visit any of
our Sites or use anyfeaturesorresourcesavailableon or througha Site.
* Registration details: We may collect or obtain your Personal Data when you
use, or register to use, any of our Sites, Apps, or services.
* Content and advertising information: If you choose to interact with any third
party content or advertising on a Site or in an App, we may receive Personal
Data about you from the relevant third party.
* Third party information: We may collect or obtain your Personal Data from
third parties who provide it to us (e.g., credit reference agencies; law
enforcement authorities; etc.).
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(C) CREATION OF PERSONAL DATA
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We may also create Personal Data about you, such as records of your interactions
with us, and details of your purchase history for internal administration
purposes and analysis.
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(D) CATEGORIES OF PERSONAL DATA WE MAY PROCESS
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* Summary – Categories of Personal Data we may Process
* We may Process: your personal details (e.g., your name); demographic data
(e.g., your age); your contact details (e.g., your address); records of your
consents; purchase details; payment details (e.g., your billing address);
information about our Sites and Apps (e.g., the type of device you are
using); details of your employer (where relevant); information about your
interactions with our content or advertising; and any views or opinions you
provide to us.
We may Process the following categories of Personal Data about you:
* Personal details: given name(s); preferred name; and photograph.
* Demographic information: gender; date of birth/age; nationality; salutation;
jobtitle/industry; and language preferences.
* Contact details: correspondenceaddress; telephone number; email address; and
details of your public social media profile(s).
* Consent records: records of any consents you may have given, together with
the date and time, means of consent and any related information (e.g., the
subject matter of the consent).
* Purchase details: records of purchases and prices.
* Payment details: invoice records; payment records;billing address; payment
method; bank account number or credit card number; cardholder or
accountholder name; card or account security details; card ‘valid from’ date;
and card expiry date;BACS details; SWIFT details; IBAN details; payment
amount; payment date; and records of cheques.
* Data relating to our Sites and Apps: device type; operating system; browser
type; browser settings; IP address; language settings; dates and times of
connecting to a Site; App usage statistics; App settings; dates and times of
connecting to an App; location data,and other technical communications
information (some of which may constitute Personal Data); username; password;
security login details; usage data; aggregate statistical information.
* Employer details: where you interact with us in your capacity as an employee,
the contact information of your employer (including name, address, telephone
number and email address)to the extent relevant.
* Content and advertising data: records of your interactions with our online
advertising and content, records of advertising and content displayed on
pages or App screens displayed to you, and any interaction you may have had
with such content or advertising (including mouse hover, mouse clicks, any
forms you complete (including incomplete forms not submitted) and any
touchscreen interactions).
* Views and opinions: any views and opinions that you choose to send to us, or
publicly post about us on social media platforms.
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(E) LAWFUL BASIS FOR PROCESSING PERSONAL DATA
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* Summary – Lawful basis for Processing Personal Data
* We may Process your Personal Data where: you have given your prior, express
consent; the Processing is necessary for a contract between you and us; the
Processing is required by applicable law; the Processing is necessary to
protect the vital interests of any individual; or where we have a valid
legitimate interest in the Processing.
In Processing your Personal Data in connection with the purposes set out in this
Policy, we may rely on one or more of the following legal bases, depending on
the circumstances:
* Consent: We may Process your Personal Data where we have obtained your prior,
express consent to the Processing (this legal basis is only used in relation
to Processing that is entirely voluntary – it is not used for Processing that
is necessary or obligatory in any way);
* Contractual necessity: We may Process your Personal Data where the Processing
is necessary in connection with any contract that you may enter into with us;
* Compliance with applicable law: We may Process your Personal Data where the
Processing is required by applicable law;
* Vital interests: We may Process your Personal Data where the Processing is
necessary to protect the vital interests of any individual; or
* Legitimate interests: We may Process your Personal Data where we have a
legitimate interest in carrying out the Processing for the purpose of
managing, operating or promoting our business, and that legitimate interest
is not overridden by your interests, fundamental rights, or freedoms.
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(F) SENSITIVE PERSONAL DATA
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* Summary – Sensitive Personal Data
* We do not seek to collect or otherwise Process your Sensitive Personal Data.
Where we need to Process your Sensitive Personal Data for a legitimate
purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process your Sensitive Personal Data in
the ordinary course of our business. Where it becomes necessary to process your
Sensitive Personal Data for any reason, we rely on one of the following legal
bases:
* Compliance with applicable law: We may Process your Sensitive Personal Data
where the Processing is required or permitted by applicable law (e.g., to
comply with our diversity reporting obligations);
* Detection and prevention of crime: We may Process your Sensitive Personal
Data where the Processing is necessary for the detection or prevention of
crime (including the prevention of fraud);
* Establishment, exercise or defence of legal rights: We may Process your
Sensitive Personal Data where the Processing is necessary for the
establishment, exercise or defence of legal rights; or
* Consent: We may Process your Sensitive Personal Data where we have, in
accordance with applicable law, obtained your prior, express consent prior to
Processing your Sensitive Personal Data (this legal basis is only used in
relation to Processing that is entirely voluntary – it is not used for
Processing that is necessary or obligatory in any way).
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(G) PURPOSES FOR WHICH WE MAY PROCESS YOUR PERSONAL DATA
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* Summary – Purposes for which we may Process your Personal Data
* We may Process your Personal Data for the following purposes: providing
services to you; operating our Sites and Apps; communicating with you;
managing our IT systems; health and safety; financial management; conducting
surveys; ensuring the security of our premises and systems; conducting
investigations where necessary; compliance with applicable law; and improving
our Sites, Apps, and services.
The purposes for which we may Process Personal Data, subject to applicable law,
include:
* Provision of services to you: providing our Sites, Apps, andservices to you;
communicating with you in relation to those services, andproviding you with
promotional items at your requestor in connectionwith those servicesor
similar services.
* Our Sites and Apps: operating and managing our Sites and our Apps; providing
content to you; displaying advertising and other information to you;
communicating and interacting with you viaour Sites and our Apps; identifying
issues with our Sites and Apps and planning improvements to or creating new
Sites and Apps; and notifying you of changes to any of our Sites, our Apps,
or our services.
* Communications: communicating with you viaany means (including viaemail,
telephone, text message, social media, post or in person) news items and
other information in which you may be interested, subject to ensuring that
such communications are provided to you in compliance with applicable law;
maintaining and updating your contact information where appropriate; and
obtaining your prior, opt-in consent where required.
* Communications and IT operations: management of our communications systems;
operation of IT security systems; and IT security audits.
* Health and safety: health and safety assessments and record keeping; and
compliance with related legal obligations.
* Financial management: sales; finance; corporate audit; and vendor management.
* Surveys: engaging with you for the purposes of obtaining your views on our
services.
* Security: physical security of our premises (including records of visits to
our premises; and CCTV recordings); and electronic security (including login
records and access details).
* Investigations: detecting, investigating and preventing breaches of policy,
and criminal offences, in accordance with applicable law.
* Legal proceedings: establishing, exercising and defending legal rights.
* Legal compliance: compliance with our legal and regulatory obligations under
applicable law.
* Improving our Sites, Apps, services: identifying issues with our Sites, our
Apps, or our services; planning improvements to our Sites, our Apps, or our
services; and creating newSites, Apps, or services.
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(H) DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
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* Summary – Disclosure of Personal Data to third parties
* We may disclose your Personal Data to: legal and regulatory authorities; our
external advisors; our Processors; any party as necessary in connection with
legal proceedings; any party as necessary for investigating, detecting or
preventing criminal offences; any purchaser of our business; and any third
party providers of advertising, plugins or content used on our Sites or our
Apps.
We may disclose your Personal Data to other entities within the Companygroup,
for legitimate business purposes (including operating our Sites and our Apps,
and providing services to you), in accordance with applicable law.In addition,
we may disclose your Personal Data to:
* legal and regulatory authorities, upon request, or for the purposes of
reporting any actual or suspected breach of applicable law or regulation;
* outside professional advisors (such as accountants, auditors, or
lawyers),subject to binding contractual obligations of confidentiality;
* third party Processors (such as payment services providers; data centers;
etc.), located anywhere in the world, subject to the requirements noted below
in this Section (H);
* any relevant party, law enforcement agency or court, to the extent necessary
for the establishment, exercise or defence of legal rights;
* any relevant party for the purposes of prevention, investigation, detection
or prosecution of criminal offences or the execution of criminal penalties,
including safeguarding against and the prevention of threats to public
security;
* any relevant third party acquirer(s), in the event that we sell or transfer
all or any relevant portion of our business or assets (including in the event
of a reorganization, dissolution or liquidation); and
* any relevant third party provider, where our Sites and our Apps use third
party advertising, plugins or content. If you choose to interact with any
such advertising, plugins or content, your Personal Data may be shared with
the relevant third party provider. We recommend that you review that third
party’s privacy policy before interacting with its advertising, plugins or
content.
If we engage a third-party Processor to Process your Personal Data, the
Processor will be subject to binding contractual obligations to: (i) only
Process the Personal Data in accordance with our prior written instructions; and
(ii) use measures to protect the confidentiality and security of the Personal
Data; together with any additional requirements under applicable law.
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(I) INTERNATIONAL TRANSFER OF PERSONAL DATA
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* Summary – International transfer of Personal Data
* We may transfer your Personal Data to recipients in other countries. Where we
transfer Personal Data from the EEA to a recipient outside the EEA that is
not in an Adequate Jurisdiction, we do so on the basis of Standard
Contractual Clauses.
Because of the international nature of our business, we may need to transfer
your Personal Data within the Companygroup, and to third parties as noted in
Section (H)above, in connection withthe purposes set out in this Policy. For
this reason, we may transfer your Personal Data to other countries that may have
different laws and data protection compliance requirements to those that apply
in the country in which you are located.
Where we transfer your Personal Data from the EEA to recipients located outside
the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard
Contractual Clauses.You may request a copy of our Standard Contractual Clauses
using the contact details provided in Section (R)below.
Please note that when you transfer any Personal Data directly to a Company
entityestablished outside the EEA, we are not responsible for that transfer of
your Personal Data. We will nevertheless Process your Personal Data, from the
point at which we receive thedata, in accordance with the provisions of this
Privacy Policy.
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(J) DATA SECURITY
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* Summary – Data security
* We implement appropriate technical and organisational security measures to
protect your Personal Data. Please ensure that any Personal Data that you
send to us is sent securely.
We have implemented appropriate technical and organisational security measures
designed to protect your Personal Data against accidental or unlawful
destruction, loss, alteration, unauthorised disclosure, unauthorised access, and
other unlawful or unauthorised forms of Processing, in accordance with
applicable law.
Because the internet is an open system, the transmission of information viathe
internet is not completely secure. Although we will implement all reasonable
measures to protect your personal data, we cannot guarantee the security of your
data transmitted to us using the internet – any such transmission is at your own
risk and you are responsible for ensuring that any Personal Data that you send
to us are sent securely.
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(K) DATA ACCURACY
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* Summary – Data accuracy
* We take every reasonable step to ensure that your Personal Data are kept
accurate and up-to-date and are erased or rectified if we become aware of
inaccuracies.
We take every reasonable step to ensure that:
* your Personal Data that we Process are accurate and, where necessary, kept up
to date; and
* any of your Personal Data that we Process that you inform us isinaccurate
(having regard to the purposes for which they are Processed) are erased or
rectified.
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(L) DATA MINIMISATION
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* Summary – Data minimisation
* We take every reasonable step to limit the volume of your Personal Data that
we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process
are limited to the Personal Data reasonably necessary in connection with the
purposes set out in this Policy or as required to provide you services or access
to our Apps and Sites.
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(M) DATA RETENTION
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* Summary – Data retention
* We take every reasonable step to ensure that your Personal Data are only
retained for as long as they are needed.
We take every reasonable step to ensure that your Personal Data are only
Processed for the minimum period necessary for the purposes set out in this
Policy.
The criteria for determining the duration for which we will keep your Personal
Data are as follows: we will retain copies of your Personal Data in a form that
permits identification only for as long as is necessary in connection with the
purposes set out in this Policy, unless applicable law requires a longer
retention period. In particular, we may retain your Personal Data for the
duration of any period necessary to establish, exercise or defend any legal
rights.
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(N) YOUR LEGAL RIGHTS
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* Summary – Your legal rights
* Under applicable law, you may have a number of rights, including: the right
not to provide your Personal Data to us; the right of access to your Personal
Data; the right to request rectification of inaccuracies; the right to
request the erasure, or restriction of Processing, of your Personal Data; the
right to object to the Processing of your Personal Data; the right to have
your Personal Data transferred to another Controller; the right to withdraw
consent; and the right to lodge complaints with Data Protection Authorities.
We may require proof of your identity before we can give effect to these
rights.
Subject to applicable law, you may have a number of rights regarding the
Processing of your Relevant Personal Data, including:
* the right not to provide your Personal Data to us (however, please note that
we may be unable to provide you with the full benefit of our Sites, our Apps,
or our services, if you do not provide us with your Personal Data – e.g., we
may not be able to process your orders without the necessary details);
* the right to request access to, or copies of, your Relevant Personal Data,
together with information regarding the nature, Processing and disclosure of
those Relevant Personal Data;
* the right to request rectification of any inaccuracies in your Relevant
Personal Data;
* the right to request, on legitimate grounds:
* erasure of your Relevant Personal Data; or
* restriction of Processing of your Relevant Personal Data;
* the right to object, on legitimate grounds, to the Processing of your
Relevant Personal Data by us or on our behalf;
* the right to have certain Relevant Personal Data transferred to another
Controller, in a structured, commonly used and machine-readable format, to
the extent applicable;
* where we Process your Relevant Personal Data on the basis of your consent,
the right to withdraw that consent (noting that such withdrawal does not
affect the lawfulness of any Processing performed prior to the date on which
we receive notice of such withdrawal, and does not prevent the Processing of
your Personal Data in reliance upon any other available legal bases); and
* the right to lodge complaints with a Data Protection Authority regarding the
Processing of your Relevant Personal Data by us or on our behalf.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights
or any other provision of this Policy, or about our Processing of your Personal
Data, please use the contact details provided in Section(R)below.Please note
that:
* we may require proof of your identity before we can give effect to these
rights; and
* where your request requires the establishment of additional facts (e.g., a
determination of whether any Processing is non-compliant with applicable law)
we will investigate your request reasonably promptly, before deciding what
action to take.
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(O) COOKIES AND SIMILAR TECHNOLOGIES (COOKIE POLICY)
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* Summary – Cookies and similar technologies
* We may Process your Personal Data by placing or reading Cookies and similar
technologies.
What is a cookie?
A cookie is a piece of data stored on your computer and tied to information
about you. By using and browsing our Sites, you consent to the use by us and
third parties of cookies and other technologies in accordance with this Policy.
What are the different types of cookies?
First party cookies are our own cookies set by our Site, controlled by us, and
used to provide information about the usage of our Site.
Third party cookies are cookies from any other domain. Some of our business
partners (for example, third-party advertisers) may use cookies on the Site, in
emails or in our advertisements on other websites to allow them to deliver the
services they are providing. In order to create a user-friendly experience, some
of our third-party promotions and advertisements are designed to automatically
transmit users' information onto the third party's landing page when you choose
to "click" upon a third party's advertisement or promotion. We do not control
these third parties or their use of cookies. As such, this Policy covers the use
of cookies by the Company and does not cover the use of cookies by any
third-party advertisers. Please check the websites of those third parties for
details on how they use cookies.
How long do cookies stay on your computer?
Two types of cookies may be used on the Site, session cookies and persistent
cookies.
Session cookies are temporary cookies that remain in your browser or device
until you leave the site; they are deleted from your device once you leave the
Service.
Persistent cookies are small files stored on your hard drive until you delete
them or until they reach their expiry date. These may, for example, be used to
remember your preferences when you use the Site, recognize you on your return,
and enhance your experience on the Site (see more about profiles below). Use of
a persistent cookie is not linked to any personally identifiable information
while on the Site except if you choose to store your user names and PINs so that
you do not have to enter them each time you access your accounts. Then, a
persistent cookie will be stored on your computer, which is linked to your
account information. If you reject the persistent cookie, you may still use the
Site but you will be limited in some areas of it.
How do we use cookies?
We may use cookies for the following purposes (either on our own or by using
third party services):
* Authentication and Preferences: Cookies can be used to recognize you when you
visit our Sites, remember your preferences (such as languages and
communication preferences), and customize your experience with using our
Sites and Services.
* Security: Cookies may enable and support our security features and to help us
detect malicious activity.
* Advertising: Cookies allow us to bring you advertising both on and off our
Sites. We may also use a cookie to learn whether someone who saw an ad later
visited and took an action on the advertiser's site. Similarly, our partners
may use a cookie to determine whether we've shown an ad and how it performed,
or provide us with information about how you interact with ads. We may also
work with a partner to show you an ad on or off our Sites, such as after you
have visited a partner's site or application.
* Analytics: We use cookies to understand, improve, and research products,
features, and services, including when you access our Sites from other
websites, applications, or devices such as your mobile device.
* Geo-Location Information: Some devices allow applications to access real-time
location-based information (for example, GPS). Some photos or other contact
you place within our Service may contain recorded location information. We
may use this information to optimize your experience. Also, some of the
information we collect from a device, for example IP address, can sometimes
be used to approximate a device’s location.
* Flash Cookies: We may, in certain situations, use Adobe Flash Player to
deliver special content, such as video clips or animation. Flash cookies are
stored on your device, but they are managed through an interface that is
different from the one provided by your web browser. This means that it is
not possible to manage Flash cookies at the browser level in the same way you
would manage other types of cookies. Instead, you can access your Flash
management tools from Adobe’s website directly.
What other technologies so we use?
* Log Files: Like most websites, our servers use log files to analyze trends,
administer our sites, track user’s movement in the aggregate, and gather
broad demographic information for aggregate use. The log file information
consists of IP addresses, browser type, browser language, referring URL,
platform type, etc., and is not linked to identifiable personal information.
* Clear Gifs: Clear gifs are tiny graphics with a unique identifier, similar in
function to cookies, and we may use them to track the online movements of our
users. Clear gifs are invisible on the page and are much smaller than
cookies, about the size of the period at the end of this sentence. We may
also use clear gifs in our HTML-based emails to let us know which emails have
been opened by the recipients. This allows us to gauge the effectiveness of
certain communications and the effectiveness of our marketing campaigns.
* Profile: We may store information that we collect to create a profile of our
users. A profile is stored information that we keep on individual users that
detail their viewing preferences. Consequently, collected information may be
tied to users' personally identifiable information to improve the content of
the Site for users, improve our Services and provide new services that are
likely to be of interest to users and to direct pertinent product updates and
marketing promotions to users if they have opted in to receive those
promotions. We do not share personally identifiable elements of a user’s
profile with other third parties. User profiles are shared in aggregate form
only.
* Do Not Track Response: Certain web browsers may allow you to enable a “do not
track” option that sends signals to the websites you visit indicating that
you do not want your online activities tracked. This is different from
blocking cookies as browsers with the “do not track” option selected may
still accept cookies. Right now, there is no industry standard for how
companies should respond to “do not track” signals, although one may be
adopted in the future. We do not respond to “do not track” signals at this
time. If we do so in the future, we will modify this Privacy Policy
accordingly. More information about “do not track” is available at
www.allaboutdnt.org.
Can I Change My Cookie Preferences?
Browser settings allow you to choose whether or not to accept cookies or limit
certain cookies. Most browsers also provide functionality that lets you review
and erase cookies. If you use our Sites without changing your browser settings,
we will assume that you are happy to receive all cookies on our Sites. Please be
aware that if cookies are disabled, not all features of the Site may operate as
intended.
Your mobile operating system may let you opt out from having your information
collected or used for interest-based advertising on mobile devices. You should
refer to the instructions provided by your mobile device’s manufacturer, but
this functionality is usually available in the “Settings” section of your
device. You can also stop us from collecting information through our
applications by uninstalling our applications.
For more information about these specialized cookies and other technologies, and
to learn more about behavioral advertising or to opt out of this type of
advertising for some companies, you can visit http://www.networkadvertising.org
or http://networkadvertising.org/optout_nonppii.asp.
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(P) TERMS OF USE
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* Summary – Terms of Use
* The Terms and Conditions located on our website will govern all use of our
Sites and our Apps.
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(Q) DIRECT MARKETING
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* Summary – Direct marketing
* We may Process your Personal Data to contact you with information regarding
services that may be of interest to you. You may unsubscribe for free at any
time.
We may Process your Personal Data to contact you via email, telephone, direct
mail or other communication formats to provide you with information regarding
services that may be of interest to you. If we provide services to you, we may
send information to you regarding our services, upcoming promotions and other
information that may be of interest to you, using the contact details that you
have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by following the
unsubscribe instructions included in every promotional email we send. Wewill not
send you promotional emailsfrom a list you have selected to be unsubscribed
from, but we may continue to contact you to the extent necessary for the
purposes of any services you have requestedor from additional lists you have
signed up under.
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(R) CONTACT DETAILS
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* Summary – Contact Detials
* You may contact us at:
Sender Team LLC.
Central prospectus, House 73
Mykolaiv region, Mykolaiv city
Ukraine
54017
Email: info@sender.team
If you wish to be taken off our contact list for direct marketing, or if you
have any comments, questions or concerns about any of the information in this
Policy, or any other issues relating to the Processing of Personal Data carried
out by us, or on our behalf, please contact:
Sender Team LLC.
Central prospectus, House 73
Mykolaiv region, Mykolaiv city
Ukraine
54017
Email:
info@sender.team
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(S) DEFINITIONS
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* “App” means any application made available by us (including where we make
such applications available viathird party stores or marketplaces, or by any
other means).
* “Adequate Jurisdiction” a jurisdiction that has been formally designated by
the European Commission as providing an adequate level of protection for
Personal Data.
* “Cookie” means a small file that is placed on your device when you visit a
website (including our Sites). In this Policy, a reference to a “Cookie”
includes analogous technologies such as web beacons and clear GIFs.
* “Controller”means the entity that decides how and why Personal Data are
Processed. In many jurisdictions, the Controller has primary responsibility
for complying with applicable data protection laws.
* “Data Protection Authority” means an independent public authority that is
legally tasked with overseeing compliance with applicable data protection
laws.
* “EEA” means the European Economic Area.
* “Personal Data” means information that is about any individual, or from which
any individual is directly or indirectly identifiable, in particular by
reference to an identifier such as a name, an identification number, location
data, an online identifier or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural or social
identity of that individual.
* “Process”, “Processing” or “Processed”means anything that is done with any
Personal Data, whether or not by automated means, such as collection,
recording, organisation, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or
destruction.
* “Processor”means any person or entity that Processes Personal Data on behalf
of the Controller (other than employees of the Controller).
* “Relevant Personal Data” means Personal Data in respect of which we are the
Controller. It expressly does not include Personal Data of which we are not
the Controller.
* “Sensitive Personal Data” means Personal Data about race or ethnicity,
political opinions, religious or philosophical beliefs, trade union
membership, physical or mental health, sexual life, any actual or alleged
criminal offences or penalties, national identification number, or any other
information that may be deemed to be sensitive under applicable law.
* “Standard Contractual Clauses” means template transfer clauses adopted by the
European Commission or adopted by a Data Protection Authority and approved by
the European Commission.
* “Site”means any website operated, or maintained, by us or on our behalf.
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(T) VIETNAM PRIVACY POLICY
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* More information about “VIETNAM PRIVACY POLICY” is available at VIETNAM
PRIVACY POLICY page.
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