Last Updated: January 15, 2020
We, loyalbutler.com / Greeneganta Inc (the “Company”, “us”, “our” or "we"), are committed to the protection of our users’, subscribers’, members’ and visitors’ (“you”, “you” or “users”) information. We recognize the importance of protecting all information that you may choose to share with us.
“Personal Information” means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, date of birth, address, phone number, email address, username, password, language preference, method of payment/billing information (such as your credit card or debit card) and any other information that is required by applicable law to be treated as Personal Information.
“Processing” means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Protection Principles
Your privacy is important to us, as such, we promise to follow the following data protection principles:
· Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Information. We will provide you information regarding Processing upon request.
· Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Information was gathered.
· Processing is done with minimal data. We only gather and process the minimal amount of Personal Information required for any purpose.
· Processing is limited with a time period. We will not store your Personal Information for longer than needed or required by law.
· We will do our best to ensure the accuracy of your Personal Information.
· We will do our best to ensure the integrity and confidentiality of your Personal Information.
Data We Collect About You
Information Provided by You
We, as the Controller, collect your Personal Information upon your consent for the purpose of providing you with the Services. Generally, Personal Information is collected when you create an account (your “Account”), select a membership, subscribe to a newsletter or email list, participate in a survey, contest, sweepstakes, event or promotion, purchase, access, stream or download content through our Services, refer others to our Services, interact with us via social media sites, contact our customer service or request technical support, or otherwise communicate with us. Whatever the activity may be, we will only collect information to the extent deemed reasonably necessary to fulfil your requests and our legitimate business objectives.
Information Automatically Collected About You
Log Information: When you access the Services, we log information about your use of the Services, including your Internet Protocol (“IP”) address, web request, access times, pages viewed, content you purchased, access, streamed or downloaded, web browser, links clicked and the page you visited before navigating to our Services.
Cookies: When you access the Services, we or one of our advertising partners, may send one or more cookies to your computer. A "cookie" is a small bit of record-keeping information that websites often store on a user's computer. Cookies do not include people's names, email addresses, or other information that is personally identifiable; they are typically used to quickly identify a user's computer and to "remember" things about the user's visit. We may set cookies for your web browser as you visit our websites, use our products and Services or visit a website where we provide ads, content or analytics. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to view, use or access certain features of our Services. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
Device Information: We also collect information about the mobile device or computer you use to access the Services, including the hardware model, operating system and version, unique device identifiers, device accounts, device state and mobile network information.
Geographic location: we may determine your general geographic location, provide localized content, provide you with customized and personalized reading recommendations for content we think will be of interest to you, determine your interests to quickly and efficiently respond to your inquiries and requests.
Interest Based Ads: We also use ad serving technologies that may collect information as a result of ad serving in the products and services, and that may temporarily display advertisements on the Services and Service Provider sites. The information collected and used for the interest based advertising may contain the following, without limitation: age and gender, number of views of an advertisement, device unique identity or other device identifiers and settings, information about your use of the products and Services and other Internet sites (including Service Provider web pages and mobile Internet sites) viewed by you (as well as date and time viewed), advertisement(s) served and response to the advertisement(s) (if any).
How We Use Your Personal Information
We will only use your Personal Information when the law allows us to. Specifically, we use your Personal Information for the following:
· To provide, personalize, and improve the Services and other services and products provided by us, for example by providing customized, personalized, or localized content, recommendations, features, and advertising on or outside of the Service (including for third party products and services);
· To understand how you access and use the Services to ensure technical functionality of the Services, develop new products and services, and analyze your use of the Services, including your interaction with applications, advertising, products, and services that are made available, linked to, or offered through the Services;
· To communicate with you for purposes related to the Services;
· To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of the Services;
· To communicate with you, either directly or through one of our service providers, for marketing, research, participation in contests, surveys and sweepstakes, or promotional purposes, via emails, notifications, or other messages, consistent with any permissions you may have communicated to us. If you do not wish for us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described herein.
· To provide you with features, information, advertising, or other content which is based on your specific location.
Sharing Your Personal Information
We do not share your Personal Information with just anyone. We share your Personal Information only as described below:
· Service Providers: We use other companies, agents or contractors (“Service Providers”) which may be located in or outside of the European Union, to perform certain services on our behalf to assist us in the provision of the Services to you. For example, we engage Service Providers to provide marketing, advertising, communications, promotional offers, infrastructure and IT services (in particular, hosting, storing, managing, and maintaining our applications, content and the data we process); to personalize and optimize our Service; to process credit card transactions or other payment methods; to update your credit card information; to provide internal audit, management, billing or administrative services; to provide fraud prevention and management services; to provide customer service and support, to provide to collect debts, to analyze and enhance data, and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your Personal Information needed to provide such services, but may not use or disclose it for any other purpose.
· Business Partners: We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. We require our affiliates and business partners to agree to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which it was provided.
· Law Enforcement and Data Protection Agencies: We will share your Personal Information when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law; enforce our Terms of Service; or respond to valid legal process, such as a court order, or a subpoena. We also will share your Personal Information where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person; provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your Personal Information. This includes sharing your Personal Information with other companies and organizations for fraud protection and credit risk reduction.
Data Retention and Deletion
We keep your Personal Information as long as necessary to provide you with the Services and for legitimate and essential business purposes, such as maintaining the performance of our Services, making data-driven business decisions, complying with our legal obligations, and resolving disputes.
Your right to be forgotten. If you request (such request can be made by sending an email to [email protected]), we will delete or anonymize your Personal Information you shared with us so that it no longer identifies you, unless, we are legally allowed or required to maintain certain Personal Information, including situations such as the following:
· If there is an unresolved issue relating to your Account, we will retain the necessary Personal Information until the issue is resolved;
· Where we are required to retain the Personal Information for our legal, tax, audit, and accounting obligations, we will retain the necessary Personal Information for the period required by applicable law; and/or,
· Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
Transfer to Other Countries
Many of our partners and Service Providers are located internationally, as such, their Processing of your Personal Information will involve a transfer of data outside of your country of origin. In such cases, we take every effort to ensure the degree of protection that is required to be afforded under applicable privacy laws, in particular that appropriate contractual, technical, and organizational measures are in place to protect your Personal Information.
How We Protect Your Personal Information
The security of your Personal Information is important to us. We implement generally accepted technical and organizational measures to help protect the security of your Personal Information. We have implemented various policies including pseudonymization, and encryption, using Standard Secure Sockets Layer (SSL) software, to guard against unauthorized access and unnecessary retention of Personal Information in our systems. However, it is important to realize that no system is ever completely secure. Therefore, while we strive to protect your Personal Information, we cannot guarantee its absolute security.
It is important to remember that your password protects your Account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Services.
We will notify you and any applicable regular of a breach where we are legally required to do so.
Personal Information of Children
Our Services are offered to you if you are 18 years of age or older. If you are under the age of 18, please do not use or access the Services at any time or in any manner. Protecting the Privacy of youth is especially important to us and as such, we do not knowingly collect or maintain Personal Information from persons under the age of 18. If you are the parent or legal guardian of a child under the age of 18 who has used, accessed or subscribed to our Services, please contact us to have that child’s account terminated and information deleted.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Information. This includes the following:
Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to Processing (see below), where we may have processed your Personal Information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and you consider that it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you contest the data’s accuracy, for the period necessary for us to verify the accuracy of the data; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, for the period necessary for us to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to Personal Information being processed by automated means which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent (Opt-Out) at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or any processing carried out on other legal bases. If you withdraw your consent, we may not be able to provide certain products or the Services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of your rights set out above, please contact us at [email protected]
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