Last Updated: May 23, 2022
Section 1. Summary Information
- To the extent that we collect information, including Non-Personal Information and Personal Information (both defined below) from you, this may be done in two ways: information that we collect in connection with your use of our Services and information that you give to us.
- Your Personal Information may be shared by us with third-parties in many ways, including to provide you with the Services, fulfill your Order, or for our or their own purposes. To learn more about our rights to share your information, please see the How Do We Share This Information? section below.
- In some circumstances we allow you to review and update your Personal Information by contacting us here.
- While we use commercially reasonable efforts to secure your information, we cannot guarantee and you should not expect, that your information will remain secure at all times and in all circumstances.
- Our Services are not directed to children under 13. Please see the Age Limitation section below for further information regarding our policy in this regard.
Section 2. What Information Do We Collect?
The information we collect about you may include the following:
- Information you provide us. We collect the content, communications, and other information you provide when you contact us, including your email address, as well as your name, address, phone number, and payment and billing information in certain circumstances.
- Information we obtain from your use of our Services. We collect information about the Services that you use and how you use them. This information includes:
- Device Information
We collect device-specific information (such as your hardware model and operating system version).
- Log Information
When you use our Services or view content provided by the Company, we automatically collect and store certain information in server logs. This includes:
- Internet protocol address (“IP Address”)
- The type of browser you are using when using our Services, including your browser's "user agent" (e.g., Internet Explorer, Safari, and other browsers)
- Device event information such as crashes, system activity, hardware settings, browser language, and the date and time of your request and referral URL
- Your geographic location
- The Domain name of your Internet service provider
- The source of traffic acquisition
- Date of traffic acquisition, and
- Website activity
Section 3. How Do We Use This Information?
We are able to deliver, personalize, and improve our Services by combining and using the information that we have about you to understand how you use and interact with our Services. We also may use the information that we have about you for the following purposes:
- To provide, maintain, improve, and develop relevant features, Content, and Services.
- To fulfill and service your Orders.
- To communicate with you by responding to your requests, comments, and questions, including through any contact information (email or mobile text number) you provide us.
- To help advertisers and publishers connect with you to offer relevant advertising in their apps and websites.
- To create analytics and reports for internal purposes. These analytics and reports may include aggregate or anonymous information.
- To detect and defend against fraudulent, abusive, or unlawful activity.
- As necessary to comply with applicable laws.
- In connection with a merger or sale or potential sale of the Company with a third party.
In connection with the foregoing, we may combine your Personal Information that we have with other information that we obtain from service providers or other companies. We may also combine your Personal Information with Non-Personal Information. When Personal Information and Non-Personal Information is combined, it will be treated as Personal Information for the duration of such combination.
Section 4. How Do We Share This Information?
We will not share the Personal Information we collect about you with any third party for their own marketing purposes without your consent. Except as set forth below, we do not sell, license, or share information that individually identifies our users with companies, organizations, or individuals outside of the Company and its affiliated entities. We will share your information in the following ways:
- Companies within the Company’s group of companies:We may share your information with our parent company and our affiliates, which are entities under common ownership or control of our ultimate parent company.
- Fraud prevention:We may disclose the Personal Information we collect about our users, including you, when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of us, our users, or others.
- Law enforcement purposes and public safety:If requested or required by government authorities, such as law enforcement authorities, courts, or regulators, or otherwise to comply with the law, we may disclose any information we have about our users. We may disclose information collected about you in order to exercise or protect legal rights or defend against legal claims. We also may be required to disclose a user’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- Sale or merger of our business:We may transfer your Personal Information to a third party if we or any of our affiliates are involved in a corporate restructuring (e.g., a sale, merger, or other transfer of assets).
We may currently or in the future use web analytics companies to assist us in measuring the effectiveness of our Services. This requires that we allow such web analytics companies to include their own Web beacons and cookies on the Services. These web analytics companies collect information from Web beacons and cookies such as click-throughs by users and other similar information. We use this information to help us learn things like overall user preferences, click-through rates, means to improve our Services, and what the types of offers that are of most interest to our users. We control how that data may be used, notwithstanding its collection by third party web analytics companies.
Common ID Cookie
Advertising Privacy Settings
FOR EU USERS ONLY: When you use our site, pre-selected companies may access and use certain information on your device and about your interests to serve ads or personalized content. You may revisit or change consent-choices at any time by clicking here.
Section 6. How Long Do We Keep the Information?
We retain the information we collect about and from you for as long as necessary to fulfill a business purpose (e.g., an Order) or comply with a legal request. We may also choose to anonymize certain information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.
Section 7. How Do We Protect Your Personal data?
Section 8. Third-Party Practices
Applicable law obligates our service providers to protect the privacy of certain types of data. We are not responsible for their actions or omissions in any way, including with respect to any information they receive directly or indirectly from us. If you believe that any party who claims association with us, including our service providers, is improperly collecting, or using information about you, you should contact them directly. You may also notify us by contacting us here, though we maintain no responsibility to reply to such correspondence or to take any action in connection with such correspondence.
In order to provide or enable certain portions of our Services, our service providers may request or require you to provide information, including Personal Information, to them or to download certain software. We have no responsibility for the privacy practices of our service providers or the contents of any software downloaded from them. Our Services may also link to third party websites and offerings over which we exercise no control. Under no circumstances shall we be responsible for the privacy practices or the content of such third-party websites and offering, including their information collection, storage, usage and sharing practices. Please contact such third parties in connection with any issues you may have with respect to those third-party websites and offerings.
Section 9. Age Limitations.
Our Services are not directed to children under the age of 13. We do not knowingly collect information, including Personal Information, from children or other individuals who are not legally able to use our Services. If we obtain actual knowledge that we have collected Personal Information from a child under the age of 13, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 13.
We comply with the Children's Online Privacy Protection Act (COPPA). For more information about COPPA and children's privacy, please click here.
Section 10. Jurisdiction and International Data Transfers
We do not represent or warrant that our Services are appropriate or available for use in any particular jurisdiction. Those who choose to access the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations. We may limit access to our Services, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.
Section 11. Accessing, Reviewing and Changing Your Personal Information.
Depending on what country (countries located in the European Economic Area for instance) or state (California or Virginia for instance) you are located in, you may have certain legal rights in relation to your Personal Information. You may have the right to request access to your Personal Information that we retain, as well as to seek to update, delete or correct this Personal Information, subject to certain exemptions provided by law. Please contact us via email here if you wish to exercise your rights. We cannot guarantee that you will be given access to your Personal Information in all circumstances, except those mandated by law. Additionally, if we are unable to verify your identity or are required to retain certain of your information by law, we may not be able to modify or delete your Personal Information, but will do so in all cases required by applicable law.
European Union Residents
We are a controller for purposes of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”). You can also contact us and the DPO here With respect to the Personal Information we collect from you, we are relying on one of the following as our legal basis to do so:
- We need the data to perform the Services requested by you or to complete the transactions requested by you.
- We have a legitimate interest in using the data in the normal manners you would expect in connection with using a service like ours.
- We need to process your data to comply with a legal requirement.
As an EU resident, GDPR affords you the following rights:
- Right to Access, which includes the right to request that we provide you with the Personal Information we have about you, the ways in which we use it, and who we share it with.
- Right to Rectification, which means you can require us to correct inaccurate Personal Information that we have about you.
- Right to Portability, which means you can request a copy of the data we have about you in a structured, machine-readable format and to ask us to send this data to another data controller.
- Right to Erasure, which means you have the right to require us to delete your Personal Information (unless prohibited by law or necessary for our legitimate purposes, including the continued provision of the Services to you).
- Right to Withdraw Consent, which means you can withdraw your consent for us to process your Personal Information.
- Right to Restrict Processing, which means you can require us to cease processing your Personal Information while undertaking rectification of such data or if we are relying on our legitimate interest to do so or if we are not fulfilling your right to erasure based on legal compliance issues.
You can exercise any of the foregoing rights by emailing us here. We will respond to requests of this nature within 30 days of your email. If you are a resident of the European Economic Area and believe we maintain your Personal Information within the scope of the GDPR, you may direct questions or complaints to us here.
Under California Civil Code Section 1798.83, which is also known as the "Shine The Light" law, users who are California residents may request from us a list of the Personal Information (if any) that we have disclosed to third parties for direct marketing purposes during in the preceding calendar year, this includes the names and addresses of such third parties. Requests may be made only one time per year. These requests are free of charge. To make a request, please contact us here or at the address or phone number set forth below. We cannot be responsible for notices that are not labeled or sent properly or that do not have complete information. In the body of such request, you must put the statement "Your California Privacy Rights", as well as your name, street address, city, state and zip code and you must provide enough information for us to determine if this applies to you. Additionally, you must attest to the fact that you are a California resident and provide a current California address.
If you are a resident of California, you have certain additional rights under the California Consumer Privacy Act of 2018 (CCPA), including the right:
- to access all data we collect about you;
- to opt-out of our sale of any of the information we collect about you to third parties;
- to have us delete any personal data (as defined under the CCPA) that we have collected about you;
- to know the categories of third parties to which we have sold data about you; and
- to know the reason we have collected data about you (as is described in our Terms).
The request for information can be sent to us at the following address:
90 N. Church Street
The Strathvale House
George Town, Grand Cayman
For more information
Section 12. E-Mail Opt Out
Section 14. Contact Us
90 N. Church Street
The Strathvale House
George Town, Grand Cayman
KY1-9012, Cayman Islands