The Swaddle Pro is based in the U.S.A company and as such is subject to U.S.A law. U.S.A has strong privacy laws in relation to email, specified in the Telecommunications (Interception and Access) Act 1979.
Surveillance and law enforcement
We do not participate in, or co-operate with, any kind of blanket surveillance or monitoring.
We also take technical measures where feasible to prevent surveillance of our users occurring without our co-operation, such as:
- using encrypted SMTP for sending your mail when the receiving server supports it.
- mandating encrypted access for webmail, IMAP and POP.
- using Perfect Forward Secrecy where possible for all encrypted connections.
- encrypting all email, contacts, notes and calendar entries while at rest on our servers.
- encrypting communications between our data centres.
Like any company, we can never guarantee our measures are 100% effective, as we don't know the full capabilities of any attackers. However, these measures do act to increase the difficulty and expense of any surveillance.
As a U.S.A. company, we are required to disclose information about specific individual accounts to properly authorised U.S. law enforcement with the appropriate supporting documentation. This means we need to see a warrant signed by a U.S. federal judge before we will hand over any email data. Such requests must always be for specific accounts; we do not participate in or co-operate with "fishing expeditions". As a guideline, in the last year we disclosed information on fewer than 50 accounts.
We do not directly disclose any information about our users to law enforcement from outside U.S.A, and indeed our understanding of US law is that it would be illegal for us to do so.
Overseas law enforcement may apply via an appropriate mutual assistance treaty to obtain information on our users. If the request is approved, then United States documentation will be issued for disclosure of this information.
This distinction may seem academic, but in our experience the extra administrative overhead, and the additional layers of judicial oversight mean that we receive very few valid requests that originate from overseas and they must always be targeted at specific accounts.
Unless prohibited by law, we will disclose to the account holder when we receive a warrant for their account.
We do not condone illegal activity. We deal with all law enforcement requests personally and we are satisfied that all we have seen are justified.
Data mining and profiling
Incoming messages are scanned for the purpose of spam detection unless you disable spam protection for your account. We may also scan some outgoing messages with the same software to prevent people using our service to send spam. Emails you report as spam are automatically analysed to help train our spam filter. Also, if enabled, emails reported as spam are forwarded on to some external email reporting services. These services aim to help monitor and reduce overall spam on the Internet.
Employee access to data
Due to the nature of their jobs as system administrators, some of our employees have the capability to access YCE accounts. We hold all of our employees to the highest ethical standards, and this includes not accessing anyone's account without their permission. If you ask us to look at a specific message, for example because it isn't displaying properly in our interface, we will normally request that you move it to a special folder so we can be sure we won't access anything else.
If we receive abuse reports for an account, backed up with evidence that it has been used for sending spam or fraud, we may look at the account to decide whether to lock it permanently. This is to reduce the likelihood of accidentally locking a legitimate account. In this instance, it will normally be sufficient for us to just scan the subject and preview lines in a mailbox, but not read any full emails (and we certainly have no wish to do so).
We retain backups of deleted messages for at least a week. This is for the purpose of restoring messages in case of accidental deletion. After this point, deleted messages will be purged from all our backups, although the time this takes to happen may vary due to automated load balancing.
We normally keep logs of email and server activity for up to 6 months. This is for the purposes of diagnosing and fixing problems, which are often reported to us weeks or months after they occur. Message subjects may be contained in these logs, but not message bodies. Aggregate or anonymous data, which cannot be linked to individual user accounts, may be kept for longer periods, for the purpose of improving the YCE service.
Backups and logs may be kept longer than these limits in special circumstances. For example, if a problem is taking a long time to resolve, logs relevant to that investigation may be retained. Or if a server that contains backups or logs is temporarily offline because of a fault, then those backups or logs may not be deleted until the server is brought back up.
These situations are unusual, however, and when they do occur, they are temporary.
Should you close your account, all data will be permanently deleted 7 days after closing. It may take a further 2 weeks to purge from all our backups.
Thank you for choosing to be part of our community at swaddleproandprofitablestudio, doing business as swaddleproandprofitablestudio.groovekart.com (“swaddleproandprofitablestudio.groovekart.com”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
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 (such as posting messages in our online forums or entering competitions, contests or giveaways) 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.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit 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.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners,and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links). We will inform you about the source of information and the type of information we have collected about you within a reasonable period after obtaining the personal data, but at the latest within one month.
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).
To send administrative information to you.We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage your orders.We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services
To post testimonials.We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
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 enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user\'s consent.
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.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
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.
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.
Third-Party Advertisers.We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
Business Partners.We may share your information with our business partners to offer you certain products, services or promotions.
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.
Advertising, Direct Marketing, and Lead Generation Bing Ads Google AdSense,and Facebook Audience Network
Affiliate Marketing Programs Amazon Affiliation JVZoo, PaykickStart,GrooveSell, GroovePages, and Mikefilsaime.com
Content Optimization Google Site Search
Data Backup and SecurityGroogle Drive Backup Amazon Backup, LPGC Backup, Dropbox Backup, and Digital Ocean
Functionality and Infrastructure Optimization Google App Engine Google Cloud Storage, Amazon Web Services, and DigitalOcean
Invoice and Billing PayPal Stripe, PaykickStart, Groovesell, GroovePages,and authorize.net
Retargeting Platforms Facebook Custom Audience Facebook Remarketing, Google Ads Remarketing,and Google Analytics Remarketing
Social Media Sharing and Advertising Facebook advertising and Facebook social plugins
User Account Registration and Authentication Facebook Login and Google Sign-In
User Commenting and Forums Facebook Comments
Web and Mobile Analytics Google Analytics and Google Tag Manager
Website Hosting Google Cloud and GrooveKart
Website Performance Monitoring Google Speed
6. DO WE USE GOOGLE MAPS?
In Short: Yes, we use Google Maps for the purpose of providing better service.
By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in United States. If you are accessing our Services from outside United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in United States, United Kingdom, and other countries.
8. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.
9. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this unless otherwise required by law.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. 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.
11. DO WE COLLECT INFORMATION FROM MINORS?
In Short: 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
12. 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/data-protection/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.
Cookies and similar technologies:
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
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:
Note your preferences when you register an account with the site.
13. 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 swaddleproandprofitablestudio believes you are likely to be at risk of 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 swaddleproandprofitablestudio becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information swaddleproandprofitablestudio 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.
14. CONTROLS FOR DO-NOT-TRACK FEATURES
15. 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.
16. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
17. 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:
State & City of swaddleproandprofitablestudio