Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Tozome. You can contact us at firstname.lastname@example.org
1. Purpose of Processing
What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to our Site and Services. If you created a profile/registered with us, you will have been asked to tick to agree to provide this information in order to access our services, purchase our products or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Site and Services.
2. Collecting your personal data
We collect information about you in the following ways:
Information You Give Us. This includes:
- the personal data that is provided by you or collected by us to enable you to sign up for and use our Site and Services. This includes your email address, birth date, gender, postal address, username, and country;
- the personal data that may be contained in any forum post, blog page, comments, or other submissions you upload or post to our Site and Services;
- the personal data that allow you to sign up and participate in Tozome contests, surveys, and sweepstakes. The exact personal data collected will vary depending on the promotion;
- the personal data you provide when you make a purchase through our Site and Services; and
- the personal data you provide when you correspond with us by phone, email, or otherwise.
Information from Social Networking Sites. our Site and Services include interfaces that allow you to connect with social networking sites (each an “SNS”). If you connect to an SNS through our Site and Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access our Site and Services. For example, when visiting Tozome, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Site and Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site and Services. We collect this information about you using cookies.
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site and Services.
We use two broad categories of cookies: (1) first-party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site and Services; and (2) third party cookies, which are served by service providers on our Site and Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our Site and Services use the following types of cookies for the purposes set out below:
Essential Cookies: These cookies are essential to provide you with services available through our Site and Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of Tozome and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies: These cookies allow Tozome to remember choices you make when you use our Site and Services, such as remembering your language preferences and remembering your login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site and Services.
Analytics and Performance Cookies: These cookies are used to collect information about traffic to Tozome and how users use our Site and Services. The information gathered does not identify any individual visitor. It includes the number of visitors to Tozome, the websites that referred them to our Site and Services, the pages they visited on Tozome, and other similar information. We use this information to help operate Tozome more efficiently, to gather broad demographic information, and monitor the level of activity on our Site and Services.
Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our Site and Services or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.
We are not responsible for advertiser Cookies or how the information gathered through their use might be used. For more information about these companies’ separate privacy policies, you should contact the company directly. Should you have any complaints about the privacy practices of any of these companies, you should contact email@example.com
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and youronlinechoices.eu.
If you do not accept our cookies, you may experience some inconvenience in your use of the Tozome. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site and Services.
4. Flash Technology
We may also use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”) on our Site and Services to collect and store information about your use of our Site and Services. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash Cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Site and Services.
5. Pixel Tags
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site and Services to track the actions of users on Tozome. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of our Site and Services so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
6. Do not track signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals.
Generally. We may use other companies to serve third-party advertisements when you visit and use our Site and Services. These companies may collect, and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to Tozome and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
8. Using your personal data
- to provide, personalize, and improve your experience with our Site and Services and other services and products provided by Tozome, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of our Site and Services (including for third party products and services).;
- to understand how you access and use our Site and Services to ensure technical functionality of our Site and Services, develop new products and services, and analyze your use of our Site and Services, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through our Site and Services;
- To communicate with you;
- To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of our Site and Services;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt-out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- where necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
9. Sharing your personal Data
We may share your personal data as follows:
Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
Our Third-Party Service Providers. We may share your personal data with our third-party service providers who provide services such as data analysis, payment processing, information technology, and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
Affiliates. We may share some or all of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.
Corporate Restructuring. We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
10. Third-party sites
Our sites and services may contain links to third-party websites and features, such as Facebook and Twitter widgets, etc. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features, or policies. Please read their privacy policies before you submit any data to them.
11. User-generated content
You may share personal data with us when you submit user-generated content to our sites and services, including via our sweepstakes, forums, message boards, and blogs on Tozome. Please note that any information you post or disclose on our Sites and Services may become public information barring instances where you are given the option to make it private and will be available to other users on our Sites and Services, and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on Tozome. Such personal data and other information will not be private or confidential once it is published on our Sites and Services.
If you provide feedback to us, we may use and disclose such feedback on Tozome, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on Tozome. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
12. International data transfer
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site and Services, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and applicable privacy laws.
We seek to use reasonable organizational, technical, and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 20 below.
14. Data retention
We keep your personal data only as long as necessary to provide you with our Site and Services and for legitimate and essential business purposes, such as maintaining the performance of our Site and Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of our Site and Services. For example, we keep your blog posts and account information.
If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
15. Our policy on children
our Site and Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, they should contact us using the details in Section 20 below. We will delete such information from our files as soon as reasonably practicable.
16. Sensitive personal data
Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through our Site and Services or otherwise to us.
If you send or disclose any sensitive personal data to us when you submit user-generated content to our Site and Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user-generated content to our Site and Services.
17. Your rights
Opt-out. You may contact us anytime to opt-out of (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of our Site and Services may be affected upon opt-out.
Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your personal data.
Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example, when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in Section 20 below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
We are committed to resolving any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at firstname.lastname@example.org. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
20. Contact Information