Privacy Policy

EFFECTIVE DATE: 05/23/2022

Click to review the previous version.

Note: The Privacy Policy has been updated. Please review the updated document carefully before using the Website. By using the Website, you consent to the terms of the updated Privacy Policy.

Sellbery (hereinafter referred to as “We”, “Us”, “Our”, “Sellbery Inc” or “Website”) is committed to protecting and respecting each User’s privacy. Our online Privacy Policy is designed to describe Our privacy practices and principles in a format that is easy to read and understand.

We have established this Privacy Policy to let Users know the kinds of information We may gather from Our Website, and related third party sites, how and why We gather the information, what We use the information for, and when We might disclose the information.

Please be advised that the practices described in this Privacy Policy apply only to information gathered by Us and any personal information We may also receive about Users from other online and offline sources, such as public databases, in connection with Our Services, which are further explained in Our Terms of Service. Each User that visits Our Website agrees to have their information and any purchases they make processed in accordance with this Privacy Policy.

Definitions

Any capitalized words not defined in this Privacy Policy shall have the meaning ascribed to them in the Terms of Service.

Acceptance of This Privacy Policy

By using Our Website and Our Services (whether or not You register or create any kind of account with Us), each User accepts the terms set forth in this Privacy Policy and the Terms of Service.  Anyone that does not agree to the terms of this Privacy Policy and the Terms of Service should not use Our Website. The only recourse for Users that do not agree to the terms of this Privacy Policy and the Terms of Service shall be to discontinue using Our Services and visiting Our Website. By using Our Website, You consent to having Your personal data transferred to and processed by Us, Our consultants and Our service providers.

Consent

By using Our Website and Services each User consents to Privacy Policy, as well as the limitation of liability, arbitration, refund policy and Our Terms of Service that form the Agreement.

Changes to This Privacy Policy

We reserve the right to revise or amend the terms of Our Privacy Policy at any time without prior notice and each User agrees that the revisions or amendments will be effective upon updating on this Website. We agree to change the “Effective date” appearing at the top of this page to reflect each time We make any changes, and it is the responsibility of each User to check back often. Continued use of Our Website and Services following the posting of changes shall mean that each User accepts those changes.

Our Privacy Policy and Terms of Service form the Agreement with each User and set out the basis on which any personal data We collect from them, or that they provide to Us, will be utilized by Us. Any Content or data We collect will only be used in accordance with this Privacy Policy and the Terms of Service. Please read the following carefully to understand Our views and practices regarding personal content, information, and data and how it​ will be treated.

Through the use of Our ​Website and any use of the Services, each User agrees to the terms provided in Our​ Privacy Policy regarding the use of their personal content, information, and data that We collect by their visiting Our Website​ and using Our Services. Users that feel Our Privacy Policy is unacceptable to them, agree and represent that their only recourse is to discontinue use of Our Website and discontinue use of the Services.

Communications From Sellbery

To improve Our Services, We may ask Users to complete surveys that We use for research purposes, although Users do not have to respond to them. We may periodically send Users information regarding the Services, updates, promotional emails, new products, special offers, or other information which We think Users may find interesting. The information will be sent to Users via email, push notifications, internal messaging, and/or another form of the notification system. In such cases, We will use the email address or other contact information provided to Us by the User.

Information We May Collect From Users

Each User agrees that Sellbery may collect the following minimum data about them:

• Name;
• Contact information, including email address, phone number;
• IP (Internet Protocol) address;
• Information supplied during the processing of registering with Us;
• Data usage trends;
• Data showing the effectiveness of promotional campaigns;
• Browser information;
• Demographic information;
• Browsing preferences and data;
• Type of device being used;
• Website usage information; and

other information relevant to surveys and/or offers, and any other information We are legally allowed to collect. We require this information to provide Users with better Services. While there will be no need in information – we immediately stop its processing.

Accessing or Signing up Through a Third-party App or Website

We may receive personal information and data about Users from third parties and combine that with information and data We collect through Our Website. For example, We may obtain information and data when Users login through a third-party social media Website, website, or authentication service, such as Facebook, Google, Reddit, and Discord. Such information and data may include email address, name, phone number, physical address, address book, contacts, and other personally identifying information. Similarly, when You interact with Us through a social media Website or third-party service, such as when You like, follow or share Sellbery content on Facebook, Twitter, or other Websites or websites, We may receive information that You permit those other Websites or websites to share with third parties. The information and data We receive from these third-party sites is dependent upon that third party’s policies and your privacy settings with them.

Heat Map and Tracking Software

We may use a Heat Map Tracking Tool (“HMTT”) to track mouse movements of Users on Our Website. The HMTT is a product experience insights tool that gives Us behavior analytics and feedback data to help Us understand Our Users through tools like heatmaps, session recordings, surveys, and an incoming feedback widget.

We may use various types of tracking software (“Tracking Software”)  to track mouse movement, scrolling, and clicks on Our Website in order to better understand Our Users’ needs and to optimize the use of Our Services. The most common form of Tracking Software is referred to as a “heat map” and the forms of heat maps include scroll maps, click maps, and movement maps. Heat maps are graphical representations of data where values are depicted by color. Users specifically agree to Our use of Tracking Software and heat maps.

Our Tracking Software may capture screenshots of Users’ mouse movements, scrolling, and clicking habits which helps Us understand what Users want, care about, and do on Our Website by visually representing their clicks, taps, and scrolling behavior. Some of the reasons why We use heat map software are as follows: to see if Users are reaching important Content or failing to see it, to find and use a page’s main links, buttons, opt-ins, and CTAs, to see if Users are getting distracted by non-clickable elements, and to compare usage against mobile, tablet and desktop devices.

We use Tracking Software to help Us better understand Our Users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what Users do and don’t like, etc.) and this enables Us to build and maintain Our Services with User feedback. This Traffic Software uses cookies and other technologies to collect data on Our Users’ behavior and their devices. This includes a device’s IP address (processed during Your visit to Our Website and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display Our Website. This Tracking Software stores this information on Our behalf in a pseudonymized User profile. The company We obtained this tracking software from is contractually forbidden to sell any of the data collected on Our behalf.

The HMTT complements the data and insights We get from traditional product and web analytics tools like Google Analytics or Mixpanel. It’s an industry-leading and easy-to-use service that combines product experience insights, User behavior analysis, and User feedback to help Us connect the dots between what’s happening on Our Website, and why it happens.

Heatmaps show Us an aggregate of User behavior on individual Website pages showing where Users click and scroll, what they are interested in, and what part of the page they may interact with and find useful.

Website heatmaps visualize the most popular (hot) and unpopular (cold) elements of Our Website using colors on a scale from red to blue.

By aggregating User behavior, heatmaps facilitate Our data analysis and give Us an at-a-glance understanding of how Users are interacting with various parts of Our Website —what they click on, scroll through, or ignore—which helps Us identify trends and optimize Our Website for further engagement.

We will solely process this personal data obtained through our HMTT in accordance with Article 6(1)(b) GDPR. As a User of Our Website, the legal basis for Us to process Your personal data is Article 6(1)(f) GDPR.

Benchmarking. We reserve the right to use and retain Your personal data in a de-identified and/or aggregated form to improve Our Website and for statistical and benchmarking purposes, including enabling comparisons within the same industry to enhance the insights collected through Our Website. Benchmarks look at all collected metrics and compare them to others of the same nature. These de-identified and/or aggregated benchmarks may be published and shared publicly within Our Website or in the form of other content We publish which may show a summary of results for a certain category or question type. No Data which can individually identify Users will ever be shown in this statistical or benchmark data.

Mouse Tracking and Recording Tool (“MTRT”)

We may use a Mouse Tracking and Recording Tool (“MTRT”). This tracking and recording software tool tracks Our Users unanimously. Technologies such as cookies, beacons, tags and scripts are used by this MTRT. These technologies may be used in analyzing trends, administering Our Website, tracking Your movements around Our Website and gathering demographic information about Our user base as a whole. We use cookies to remember users’ settings as well as for authentication and analytics. Users can control the use of cookies at the individual browser level. If You reject cookies, You may still use Our Website, but Your ability to use some features or areas of Our Website may be limited. This MTRT tool is used to track Your activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases). If You are located in Europe, Your IP address, keystroke activity, and personal information are never stored or shared with any third-parties. We process and keep all data for Our own Website within the United States and if you wish to opt-out from tracking by this MTRT please contact Us at azatserklaniy@sellbery.com. In addition to using this MTRT we may also use Google Analytics, Google Tag Manager, Google AdWords (Conversion Tracking), LinkedIn (Conversion Tracking), Share-a-Sale (Conversion Tracking), Yahoo (Conversion Tracking), and Quora (Conversion Tracking). Some or all of these tools may be used to track information about Your behavior on Our Website depending on Your region.

Storage and Processing. Your information collected through this MTRT may be stored and processed in the United States, Europe, or any other country in which the MTRT or its subsidiaries, affiliates or service providers maintain facilities. This MTRT may transfer information that We collect about You, including personal information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If You are located in the European Union or European Economic Area, please note that we will not transfer information, including personal data, to a country outside of the European Union or European Economic Area.

Website Analytics

We use multiple server-based web analytics tools provided by service partners such as Google Analytics to collect information about how You interact with Our Website or mobile applications, including what pages You visit, what site You visited prior to visiting Our Website, how much time You spend on each page, what operating system and web browser You use and network and IP information. We use the information provided by these tools to improve Our Services. These tools place persistent cookies in Your browser to identify You as a unique user the next time You visit Our Website. Each cookie cannot be used by anyone other than the service provider (example: Google for Google Analytics). The information collected from the cookie may be transmitted to and stored by these service partners on servers in a country other than the country in which You reside. The information collected is used and shared by these service providers in accordance with their individual privacy policies. You can control the technologies We use by utilizing settings in Your browser or third-party tools.

Targeted Advertisements

Targeted ads or interest-based offers may be presented to You based on Your activities on Our webpages, and other sites linked to Our Website and based on the products You currently own. These offers will display as varying product banners presented to You while browsing. We also partner with third parties to manage Our advertising. Our third-party partners may use technologies such as cookies to gather information about such activities in order to provide You with advertising based upon Your browsing activities and interests and to measure advertising effectiveness. If You are in the US or Canada and wish to opt-out of interest-based advertising visit http://preferences-mgr.truste.com If You are located in the European Union visit www.youronlinechoices.eu. Please note You will continue to receive generic ads.

What We Do With the Information We Gather

Each User agrees that Sellbery may use the information We gather as follows:  In order to process a User’s purchase of Services, We must share certain personal information every time a User signs up for Our Services. Such information may include the User’s email address, physical address, phone number, and payment information. Our service representatives may use Your telephone number or e-mail address to notify You of the status of Your purchase as necessary and appropriate. We may share User information with vendors, business clients, and other third-party providers who are performing services for Us. We may also use User information for internal record keeping and data analysis. For Our statistical purposes, We gather details of User visits to Our Website and the information that Users access, including, but not limited to, traffic data, location data, browser usage, page visits, weblogs, and other communication data. When Users contact Us, We may keep a record of that correspondence. We also use Users information to ensure that Content from Our Website is presented in the most effective manner for a computer or mobile devices.

From time to time, personal financial information may be transmitted to facilitate transactions with Us between Users who are purchasing Our Services. We will not share such personal financial information with third parties other than those third parties such as banks, processing gateways, and merchant processors required to process a User’s purchase, and Users understand that We cannot control how the banks, processing gateways or merchant processors will use such personal financial information. Therefore, Users using this Website and the Services hereby consent to such sharing of personal financial information. Each User agrees to assume the risk and agrees that it is their responsibility to properly handle, secure, not store and destroy such personal financial information as may be necessary to protect it from misuse. Sellbery shall not be liable to Users or any third party for misuse of such Content or personal financial information.

We may disclose information We collect from Users to an affiliate or other third party in the event of any merger, sale, joint venture, assignment, reorganization, liquidation, transfer or other disposition of all or any portion of Our business, assets, or stock. We may also use aggregate personal information and data for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes as long as the end-product does not uniquely identify You or any other User of Our Website.

We may use third-party advertising companies to serve ads when Users visit Our Website. These third-party advertising companies may use advertising technologies such as cookies, web beacons, and other similar advertising technologies. These companies may use aggregated information about Your visits to Our Website and third-party sites in order to provide advertisements and promotions about Our Products and Services that We believe Users may find of interest.

We may also release Users information when We believe release is appropriate to comply with the law, enforce Our Website policies and Terms of Service, or protect Ours or other’s rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for data analysis, improving Our Services, marketing, promotional, advertising, or other uses.

By using Our Website, You consent to Our collection, disclosure, storage, and use of Your personal information in accordance with this Privacy Policy and Our Terms of Service.

Social Media, Posts, Texts, Forums, and Profiles

Each User agrees that Sellbery may make available through Our Website, third-party sites, or the Services certain forms of media either now existing or to be created in the future (for example, social media, message boards, chat functionality, videos, pictures, images, profile pages, text messaging and blogs) to which Users may be able to post Content. Please note that any Content, We, RSS providers, outside third parties, or Users provide on these various forms of media may become public, and may be available to visitors to Our Website, third party sites, and to the general public, including without limitation the ratings and reviews that accompany any pages on Our Website and third-party sites. We urge Users to exercise discretion and good manners when providing Content and deciding to disclose any personal information.

EACH USER AND CUSTOMER AGREES THAT WE SHALL NOT BE RESPONSIBLE FOR ANY LOSS CAUSED BY OUR USE OR THE USE BY ANY UNAUTHORIZED PERSON OR ENTITY, OF ANY CONTENT THAT USERS DISCLOSE THROUGH OUR WEBSITE, THIRD-PARTY SITES, OR THE USE OF THE SERVICES.

Compliance and Protection

We may use Personal Data to (legal basis for the respective processing in parentheses):

• protect Our Users rights, privacy, safety or property including by making and defending legal claims (Article 6(1)(b), (c) or (f) GDPR);
• audit Our internal processes for compliance with legal and contractual requirements and internal policies (Article 6(1)(f) GDPR);
• enforce Our Terms of Service (Article 6(1)(b) or (f) GDPR);
• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft (Article 6(1)(f) GDPR); and
• comply with the Applicable Law, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities (Article 6(1)(c) or (f) GDPR).

The legal basis for aggregating/anonymizing this Personal Data is Article 6(1)(f) GDPR.

Other Purposes with Your Consent

In some cases, We may ask You for consent (unless You have previously given it to Us) to collect, use or share Personal Data for other purposes. For example, We may ask You for consent to send marketing emails where required by law or to post testimonials or endorsements. In such cases, there will always be the ability to deny or revoke consent if desired. The legal basis for the data processing is under Article 6(1)(a) GDPR.

Information About Your Device and its Software

Information about Your device and its software includes Your IP address, browser type, internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows Us to identify Your browser, mobile device, or Your Account (including, for example, a persistent device identifier or an advertisement ID), and other similar information. We may also work with third-party partners to employ technologies, including statistical modeling tools, that permit Us to recognize and contact You across multiple devices. We use this device and software information to diagnose and fix technology problems, serve You personalized advertising, personalize Your experience, perform analytics/identify usage trends, and improve Our products and Services offered on or through Our Website.

Your rights as a data subject

According to the applicable laws, you have various rights regarding your personal data. If you wish to assert these rights, please send your request by e-mail or by post to the address specified in the section on the bottom of this Policy, clearly identifying yourself.

Right to acknowledgement and access

You have the right to receive confirmation from Us at any time as to whether personal data relating to you will be processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you together with a copy of this data.

If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees in accordance with GDPR and US data protection laws in connection with the transfer.

Right to correction

You have the right to request Us to correct any inaccurate personal data concerning you without delay.

Right for cancellation (“Right for oblivion”)

As a pursuant under GDPR and US data protection laws, you have the right to demand that we delete personal data concerning you without delay, and we are obliged to delete personal data without delay if one of the following reasons applies:

1. personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
2. you file an objection to the processing pursuant to GDPR and US data protection laws, and there are no overriding legitimate grounds for the processing, or you file an objection to the processing pursuant under conditions of GDPR and US data protection laws.
3. you withdraw your consent, on which the processing was based pursuant according to GDPR and US data protection laws, and there is no other legal basis for the processing.
4. the deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.

Right to limitation of processing

You have the right to request Us to restrict processing if one of the following conditions is met:

1. you dispute the accuracy of your personal data for a period of time that enables us to verify the accuracy of your personal data;
2. the processing is unlawful, and you have refused to delete the personal data and have instead requested the restriction of the use of the personal data;
3. We no longer need the personal data for the purposes of processing, but you do need the data to assert, exercise or defend legal claims, or
4. you have filed an objection against the processing pursuant according to GDPR and US data protection laws, as long as it is not yet clear whether the justified reasons of our company outweigh yours.

Right to transferability of data 

You have the right to receive the personal data concerning you that you have provided to us in a structured, current and machine-readable format, and you have the right to transmit this data to another person in charge without our interference, provided that

1. processing is based on consent or on a contract pursuant according to conditions of GDPR and US data protection laws and
2. processing is carried out using automated methods. When exercising your right to data transferability in accordance with paragraph 1, you have the right to request that the personal data be transferred directly by us to another person responsible, insofar as this is technically feasible.

Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you on the basis of GDPR and US data protection laws; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If We process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising.

You have the right to object to the processing of personal data concerning you, for scientific or historical research purposes or for statistical purposes in accordance with GDPR and US data protection laws, for reasons arising from your particular situation, unless the processing is necessary to fulfill a task in the public interest.

Automated decisions including profiling

You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. An automated decision making based on the collected personal data does not take place.

Right to revoke consent under data protection law

You have the right to revoke your consent to the processing of personal data at any time.

Right of appeal to a supervisory authority

You have the right of appeal to a supervisory authority.

In particular, if you have US residentship, in the Member State where you are staying, working or suspected of having infringed the law, if you believe that the processing is unlawful.

Or, if you have EU/EEA residentship, and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the authority for such issues, at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

AGE LIMITATIONS

We have no official right to collect any private information from persons who are not 18 yet. It is strictly prohibited to the Users under 18 to use Our Website and any of the Services offered by Our Company. As soon as We find out that the information presented by the User is not eligible because of the age limits, it will promptly be erased. We bear no responsibility in case if You’re not old enough to use the Website. You must be of legal age to be in line with Our Privacy Policy, as well as with Our Terms and Conditions.

Alert Us in case one of Your children under 18 is using Our Website trying to get access to our services. We’ll take measures to block access to Our Website from Your IP address. All affiliate websites cooperating with Our Company will be blocked for your child as well.

Security Not Guaranteed

Sellbery uses reasonable organizational, technical, and administrative measures to protect each User’s personal information under Our control.

We also use HTTPS encryption to protect the personal information of Our Users in order it will never be stolen or transferred anywhere without Your permission.

However, We cannot guarantee 100% percent protection and security of such personal information. Please do not email or text Us credit card information and/or other sensitive information.

Storage Time

We only store personal data for as long as is necessary to fulfill the purposes pursued. In some cases, the legislator provides for the storage of personal data, for example in tax or commercial law. In these cases, the data will only be stored by Us for these legal purposes but will not be processed in any other way and deleted after expiry of the legal retention period.

What We Don’t do with the Information We Gather

We will not disclose, sell, distribute, rent, lease or use any of a User’s data or pass on any such personal information to third parties, which are not Our officers, directors, members, managing members, employees, business partners, affiliates, strategic partners, licensors, licensees, independent contractors, third-party service providers, agents or representatives, unless We have Your permission or are required by law to do so.

We do not store Your credit card information. The credit card information and actual processing do not take place on and is not stored on Our servers. The transaction is processed on the servers of the particular credit card processor We use to process the transaction.

Security

We are committed to ensuring that personal information is secure. All non-financial information and Site Content provided to Us is stored on Our secure servers. In order to prevent unauthorized access or disclosure, We have taken all reasonable steps and put in place suitable safeguards to secure the information We collect from Users online.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect each User’s personal data, We cannot guarantee the security of their data transmitted to Our Website; any transmission is at the risk of each User. Once We have received personal information, We will use the necessary procedures and security features to try to prevent unauthorized access. We will take all reasonable steps necessary to ensure that personal information and data is treated securely and in accordance with this Privacy Policy.

Use of Cookies

Our Website uses cookies. A cookie is a small file that asks permission to be placed on a computer’s hard drive. Once someone has accepted the cookie, the file is added and the cookie helps analyze web traffic and browsing habits, such as what areas of Our Website are visited most frequently. At times We may gather information through the use of a cookie file which enables Us to gather statistical information regarding the use of Our Website. This helps Us to improve not only Our Website but the Services We can provide to Users. We may use analytical software to track user habits and trends.

We use following types of cookie files:

• Essential Cookies

These cookies are always active and necessary to the core functionality of our website and some of its features, such as access to secure areas.

• Analytics and Customization Cookies

These cookies collect information that can help us understand how our websites are being used. This information can also be used to measure effectiveness in our marketing campaigns or to curate a personalized site experience for you.

• Advertising Cookies

These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests.

Users do have the choice to decline cookies. Most web browsers automatically accept cookies, but people can usually modify their browser setting to decline cookies if they prefer. Should You choose to decline cookies You may be unable to access certain information or parts of Our Website, and some or all of the Services may not work properly. Our advertisers and promoters may also use cookies, over which We have no control.

IP Address

An IP (Internet Protocol) Address is automatically assigned to the computer that someone is using by their Internet Service Provider (ISP) and is identified and logged automatically in Our server log files whenever someone visits Our Website. This also allows Us to identify the time(s) of visit(s) and the page(s) of Our Website that have been visited. Our collecting of IP Addresses is considered a standard practice on the Internet and is done by many third-party sites.

Location Information

We may also obtain information about a User’s physical location, such as by use of GPS and other geolocation features in Your computer, laptop, or mobile device, or from other information, We collect. For example, a User’s IP Address indicates the general geographic region from which they are connecting to the Internet.

Links to Third-Party Sites

Our Website may contain links to other third party sites. However, once Users have used these links to leave Our Website, they should note that We do not have any control over the third-party site being visited. Therefore, We cannot be responsible or liable for the protection and privacy of any information provided or which is obtainable when visiting those third-party sites which are not governed by this Privacy Policy or Our Terms of Service. To the extent that You access or use the Service through or on another website, Website, or application, then the privacy policy of that other website, Website, or application will apply to Your access or use of that site or application. We encourage Our Users to read the privacy statements of other websites before proceeding to use them.

Access to and Control Over Information We Send Users

From time to time Sellbery may send Users emails about special offers, discounts, products, or Services available through the Sellbery Website. Users can opt-out of receiving Our emails by clicking the unsubscribe button in the email.

Notice to individuals in the State of California (USA)

Your Rights as a California Resident

As a California resident, you may have certain rights in relation to your personal information.

Right to Know

You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:

The categories of personal information we have collected about you.

The categories of sources from which we have collected your personal information.

The business or commercial purpose for which we collect, sell or share your personal information.

The categories of third parties to whom we have disclosed your personal information.

The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.

The categories of personal information we have “sold” to or “shared” with  third parties and the categories of third parties to whom we have “sold” or “shared” your personal information.

You may have the right to know the specific pieces of personal information we have collected about you.

Right to Make a Deletion Request

You may have the right to request that we delete your personal information that we have collected about you. Subject to certain exceptions, we must delete your personal information and direct any service provider or contractor to delete your personal information.

Right to Correct Inaccurate Personal Information

You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Opt-Out of Sales of Personal Information

You may have the right to opt-out of the sale of your personal information.

Right to Opt-Out of Sharing of Personal Information

You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.

Right to Limit Use and Disclosure of Sensitive Personal Information

Subject to certain exceptions, you may have the right to limit our use and disclosure of your sensitive personal information. We do not use or disclose sensitive personal information in a manner that gives rise to this right.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights under the CCPA.

Other Rights: Notice to California Consumers

You have other rights under California’s “Shine the Light” law. California Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes, please contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834 or by telephone at (800) 952-5210 or (916) 445-1254.

Categories of Data that We Hold about You

As mentioned above, We maintain data about you in only pseudonymized form, which means that we do not know your identity because we do not process your name, email address, or other identifiable information. Instead, we only process digital identifiers such as cookie IDs, IP addresses, mobile advertising IDs on your device, network browsing history and associated preferences, and in some limited circumstances, your hashed email address.

Why We Collect Your Personal Information

We process your Personal Information in order to provide Services and personalized advertisements to You.

Where do We Collect Your Personal Information

We automatically collect User Information when Users interact with our Services that appear on our Customers’ websites and digital properties. Like most other web-based services, we collect this User Information through cookies and other technologies. We may also obtain Information about you from our data partners.

We collect Information either directly from you during your use of our Sites and Services or from third parties that independently collect this Information from you, and we may combine the Information that we collect from these various sources. For more information about these collection methods, please see Sections above.

How do We Share Your Personal Information

We may disclose or make available your pseudonymous Personal Information to our trusted partners. In most cases when we do so, we have contractually restricted their uses of this data for only Our business purposes. Under the CCPA, such disclosures of Personal Information to service providers are not deemed to be a “sale” and thus are not prohibited after you exercise your right to cease or restrict disclosures or sales of your Personal Information to third parties. In any instances where we have not entered into a service provider relationship with such third parties, we will stop sharing your Personal Information when you instruct us not to “sell” your Personal Information.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

• Users can visit our site anonymously;
• Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website;
• Our Privacy Policy link includes the word ‘Privacy’, and can be easily found on the page specified above.

Users will be notified of any privacy policy changes on our Privacy Policy Page.

Users are able to change their personal information by emailing us.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.We do not specifically market to children under 13.

Fair Information Practices

• The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
• In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur
• We will notify the users via in site notification
• Within 7 business days

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

 

Notice to individuals in the State of Virginia (USA)

Your Rights as a Virginia Resident

As a Virginia resident, you may have certain rights in relation to your personal data.

Right to Confirm

You may have the right to confirm whether we process your personal data and to access such personal data.

Right to Delete

You may have the right to request that we delete your personal data that we have collected about you. Subject to certain exceptions, we must delete your personal data.

Right to Correct Inaccurate Personal Data

You may have the right to request that we correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of the processing of your personal data.

Right to Opt-Out of Processing of Personal Data for Targeted Advertising

You may have the right to opt-out of the processing of your personal data for purposes of targeted advertising.

Right to Opt-Out of the Sale of Personal Data

You may have the right to opt-out of the sale of your personal data.

Right to Opt-Out of Profiling

You may have the right to opt-out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Obtain a Copy of Your Personal Data

You may have the right to obtain a copy of your personal data that you previously provided to us.

Right to Non-Discrimination

You have the right to not be discriminated against by us for choosing to exercise your rights under the VCDPA.

Notice to individuals in the State of Colorado (USA)

Your Rights as a Colorado Resident

Right to Access

You have “the right to confirm whether a controller is processing personal data concerning the consumer and to access the consumer’s personal data.”

Right to Correction

You have “the right to correct inaccuracies in the consumer’s personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer’s personal data.”

Right to Delete

You  have “the right to delete personal data concerning the consumer.”

Right to Data Portability

You have “the right to obtain personal data in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance.”

Right to Opt-Out

Consumers have “the right to opt-out of the processing of personal data concerning the consumer for purposes of:

• targeted advertising
• the sale of personal data
• profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.”

Right to Appeal

According to the Colorado Privacy Act regulations, Your request must be responded to within 45 days of receipt. The covered entity may subsequently extend that deadline by an additional 45 days if they are able to show reasonable necessity. However, when the deadline is extended, You must be notified by Us within the initial 45-day response period.

Notice to individuals in the State of Utah (USA)

Your Rights as a Utah Resident

Right to access, including confirming whether a controller is processing their data, and the ability to request and receive that data;

Right to deletion of personal data, if the data subject directly provided the data to the controller;

Right to portability, obtaining a copy of their personal data that they provided to the controller, in a format that is:

• portable to a technically reasonable extent
• readily usable to a practical extent
• enables the consumer to transmit the data to another controller reasonably easily, where the processing is carried out by automated means.

Right to opt out of certain processing, specifically for the sale of the personal data or the purposes of targeted advertising;

Some rights that are present in other US state-level laws, but absent from the UCPA, include the right to opt out of profiling and the right to correct (to request and have omissions or inaccuracies in one’s personal data corrected).

We under the Utah privacy law are not required to recognize “universal opt-out signals” as a method for consumers to opt out of data processing.

Notice to individuals in the State of Connecticut (USA)

Your Rights as a Connecticut Resident:

Right to access. You have the right to confirm whether or not a controller is processing Your personal data and access such personal data. However, there is an exception to this right where such confirmation or access would require the controller to reveal a trade secret.

Right to correct. You have the right to correct inaccuracies in Your personal data, taking into account the nature of the personal data and the purposes of the processing of Your personal data.

Right to delete. You also have the right to delete personal data provided by or obtained about You.

Right to data portability. You have the right to obtain a copy of Your personal data processed by the controller, in a portable and, to the extent technically feasible, readily usable format that allows You to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided such controller shall not be required to reveal any trade secret.

The type of data You have a right to obtain a portable copy of is particularly notable. The Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) allows You to obtain a copy of the data a controller has processed about You regardless of how the controller acquired it.

Right to opt out. You have the right to opt out of the processing of the personal data for the purposes of:

• targeted advertising,
• the sale of personal data, or
• profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions;
• Process orders and to send information and updates pertaining to orders;
• We may also send you additional information related to your product and/or service.

To be in accordance with CAN SPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses;
• Identify the message as an advertisement in some reasonable way;
• Include the physical address of our business or site headquarters;
• Monitor third party email marketing services for compliance, if one is used;
• Honor opt-out/unsubscribe requests quickly;
• Allow users to unsubscribe by using the link at the bottom of each email.

Notice to the citizens of Canada

Data subjects with a residentship in Canada  have the following rights under the Privacy Act:

The right to access information – the right to both:

confirmation as to whether (or not) an agency holds information about that person; and access to such personal information, where such personal information may be readily retrieved.

The right to correction of information – the right to request correction of information. The agency must, on request or of its own initiative, take steps that are reasonable in the circumstances to ensure (having regard to the purposes for which the information may lawfully be used), the information is accurate, up to date, and not misleading.

In addition to the access and correction rights you may be entitled to exercise the right to:

object to the processing of your personal data (for instance, where we base the processing on our legitimate interests and we will stop processing your data. Except for processing related to direct marketing, we may resume processing if we can show legitimate grounds that override your rights;

request the restriction of processing of your personal data (for instance, if the data is not accurate and needs to be updated). This can also be done for data where the purposes of processing no longer apply, but you still need the data and do not want us to erase it;

request erasure of your personal data (for instance, if it’s no longer necessary for the purposes for which it was collected, if you have withdrawn consent or there is no other legal basis for processing, or if you have objected to the processing and our legitimate interests do not override your rights). Certain data may not be erased if we have a requirement to retain it for legal purposes;

request portability of your own personal data (the transfer of information you have provided to us, to another controller, in a structured, commonly used and machine-readable format), if such a request is technically possible to complete.

Also, according to Canadian legislation and specifically under both the Privacy Act (R.S.C., 1985, c. P-21) and the Personal Information Protection and Electronic Documents Act (PIPEDA) (S.C. 2000, c. 5, Assented to 2000-04-13), We collect personal information as defined by section 3 of the Privacy Act.

Notice to the citizens of Australia

The Australian Privacy Principles (or APPs) are the cornerstone of the privacy protection framework in the Privacy Act 1988 (Privacy Act). They apply to any organization or agency the Privacy Act covers.

There are 13 Australian Privacy Principles and they govern standards, rights and obligations.

The Privacy Act regulates the way individuals’ personal information is handled.

As an individual, the Privacy Act gives you greater control over the way that your personal information is handled. The Privacy Act allows you to:

• know why your personal information is being collected, how it will be used and who it will be disclosed to;
• have the option of not identifying yourself, or of using a pseudonym in certain circumstances;
• ask for access to your personal information (including your health information);
• stop receiving unwanted direct marketing;
• ask for your personal information that is incorrect to be corrected;
• make a complaint about an organization or agency the Privacy Act covers, if you think they’ve mishandled your personal information.

Notice to the citizens of Israel

Data protection in Israel is governed primarily by the Protection of Privacy Law, 5741-1981 (‘the Privacy Law’) and the regulations promulgated under it, the Basic Law: Human Dignity and Liberty, 5752-1992, and the guidelines of the Israeli regulator, the Privacy Protection Authority (‘PPA’) (formerly known as the Israel Law, Information, and Technology Authority (‘ILITA’)).

Data subjects with a residentship in Israel have the following rights under the Privacy Law:

Right to be informed

Upon collection of personal data from data subjects, a database owner must inform them: if they are under a legal duty to provide the data, the purpose of collection, and details of any third party that will receive the data and for what purpose.

Right to access

A database owner must either allow a data subject access to any data about him/her kept in the database or refuse to allow such access to the extent permitted by law.

Right to rectification and erasure

A database owner must respond to a data subject’s request to rectify or erase any data about him/her kept in the database.

Right to object/opt-out

The Privacy Law allows a data subject to object to the processing of data only by means of a civil suit based on the claim that the processing violates the data subject’s right to privacy. However, there is no established concept of a general right to object processing once the personal data has been provided for processing without violation of privacy (e.g., with the consent of the data subject).

Contact Us

Click here to contact us regarding the Privacy Policy, other privacy issues or write directly to azatserklaniy@sellbery.com.