Wednesday, February 21, 2024

Privacy Policy

Privacy Policy

Your privacy is important to us. It is Xpand Martech’s policy to respect your privacy regarding any information we may collect from you across our website, https://www.XpandMartech.com, and other sites we own and operate.

1. Information we collect

Device data

We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal information

We may ask for personal information, such as your:

  • Name
  • Email
  • Social media profiles
  • Date of birth
  • Phone/mobile number
  • Home/Mailing address
  • Work address

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

  • it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
  • we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to enable you to customize or personalize your experience of our website;
  • to enable you to access and use our website, associated applications, and associated social media platforms;
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms;
  • to run competitions and/or offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • to consider your employment application.

4. Disclosure of personal information to third parties

We may disclose personal information to:

  • Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • Our employees, contractors and/or related entities;
  • Sponsors or promoters of any competition we run;
  • Third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you; and
  • Third parties to collect and process data.

5. International transfers of personal information

The personal information we collect is stored and processed in India, where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

7. Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

9. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

10. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

This policy is effective as of April 14, 2020 – Version Française

  1. Privacy Policy Overview
  2. What Categories of Information We May Process
  3. Sensitive Personal Information
  4. How We Collect or Create Information
  5. Purposes for Which We May Process Your Information
  6. Direct Marketing
  7. Cookies, Similar Technologies and Online Behavioral Advertising
  8. What is the Lawful Basis for Processing Personal Information
  9. What Information We Disclose to Third Parties
  10. International Transfers of Information
  11. Data Security
  12. Data Accuracy
  13. Data Minimization
  14. Data Retention
  15. What Can I Do to Control My Information?
  16. Terms of Use
  17. Contact Details
  18. California Consumers
  19. How this Privacy Policy May Change
  20. Privacy Policy Overview

Summary – Policy Overview

This Policy explains how we may Process your information. This Policy may be amended or updated from time to time, so please check it regularly for updates.

Xpand Martech, LLC, with its affiliates and its subsidiaries, owns, operates, or provides access to, several interactive websites, mobile and connected applications, and other online interactive features and services, including, but not limited to, emails, newsletters, chat areas, forums, communities, sweepstakes and contests (collectively “Services”). This Privacy Policy applies to all information collected about you by Xpand Martech, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Except as otherwise noted in this Privacy Policy, Xpand Martech is a data controller (as that term is used under the EU General Data Protection Regulation (“GDPR”)), which means that we decide how and why the information you provide to us is processed. Please contact us using our DSAR Portal. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

This Privacy Policy covers information collected through the following websites.

  1. What Categories of Information We May Process

Summary – Categories of Information We May Process

We may Process your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.

Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable.

Process”, “Processing” or “Processed” means anything that is done with any 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.

We may Process the following categories of Personal Information about you:

  • Personal details: your name; username or log-in details; password; areas or topics of interest; and photograph (if you or another user posts a photo on the Service).
  • Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
  • Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
  • Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
  • Location information: location data that describes the precise geographic location of your device (“Precise Location Data”).
  • Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or accountholder name; payment amount; and payment date.
  • Employer details: where you interact with us in your capacity as an employee, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
  • Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

  • Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
  • Browsing history including the websites or other services you visited before and after interacting with the Services.
  • Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
  • Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device is derived from the IP address of such computer or device (“GeoIP Data”).
  • Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
  • Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g., iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID).
  • Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
  • Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”).
  • Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, content and ads on third party websites, applications, platforms and other media channels (“Channels”), and (ii) your interaction with emails including the content and ads therein (collectively, “Online Data”).
  • Device type, settings and software used.
  • Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
  • Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
  • Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
  • Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5.
  • Mobile analytics to understand the functionality of our mobile applications and software on your phone.

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

  1. Sensitive Personal Information

Summary – Sensitive Personal Information

We do not seek to collect or otherwise Process your Sensitive Personal Information. Where we need to Process your Sensitive Personal Information for a legitimate purpose, we do so in accordance with applicable law. The Services are not intended for use by children.

We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, “Sensitive Personal Information”) in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:

  • Compliance with applicable law: We may Process your Sensitive Personal Information where the Processing is required or permitted by applicable law;
  • Detection and prevention of crime: We may Process your Sensitive Personal Information where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
  • Establishment, exercise or defense of legal rights: We may Process your Sensitive Personal Information where the Processing is necessary for the establishment, exercise or defense of legal rights; or
  • Consent: We may Process your Sensitive Personal Information where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Information.

Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtaining coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.

  1. How We Collect or Create Information

Summary – Collection and Creation of Information

We may collect or obtain User Information about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Information public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Services; when you visit our Services; when you register to use any part of the Services; or when you interact with any third party content or advertising on the Services. We may also receive User Information about you from third parties (e.g., social network sites). We may also create User Information about you, such as records of your interactions with us. Xpand Martech is not responsible for Personal Information you volunteer about yourself in public areas of the Services. This Policy does not cover the practices of third parties who may provide information about you to Xpand Martech.

Collection of User Information: We may collect User Information about you from the following sources:

  • Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters, bulletins, webinars or white papers; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries through the Services; contact us via email, telephone or by any other means; purchase a subscription, software license or product; or when you provide us with your business card, etc.).
  • Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
  • Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
  • Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
  • Content and advertising information: If you choose to interact with any third party content or advertising on the Services or Channels, we may receive User Information about you from the relevant third party.
  • Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; social network sites or services (e.g., Facebook, Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook Connect, Twitter, or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.

Please note that Xpand Martech is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interactions, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page.

This Privacy Policy does not cover the practices of third parties, including those that may disclose information to Xpand Martech.

Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks and other data collection entities.

5. Purposes for Which We May Process Your Information

The purposes for which we may Process User Information, subject to applicable law, include:

  • Provision of the Services to You: providing the Services to you from Xpand Martech or its partners including (i) offering of contests, as well as chat areas, forums, and communities, (ii) posting of your personal testimonial alongside other endorsements, (iii) display of your personal reviews of products or services, (iv) allowing you to search for other website members using the information you may already know about that member such as username, full name or gamer profile and identify users matching that criteria, (v) management of your account, and (vi) customer support and relationship management.
  • Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
  • Surveys: engaging with you for the purposes of obtaining your views on our Services.
  • Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 6 below.
  • Advertising: providing advertising based on your interests and interactions with the Services and Channels, including using User Information to serve you advertisements on the Services and Channels, as well as licensing segments of User Information to third parties. For further information, please see Section 7 below.
  • Audience Engagement: identification and development of audience engagement, advertising and promotional strategies on various platforms and channels, both within the Service and on Channels.
  • User Engagement and Purchases: tracking purchase traffic and activity across the Service and on Channels, including review of your browsing history (if available); provision of analytics and measurement of cost of traffic against money being made.
  • Commerce Offerings: using cookies to track your browsing history and the amount of money spent at a particular third-party merchant’s site to offer coupons and other offers that are relevant to your shopping experience; offering of coupons via SMS messages if a mobile phone number is provided.
  • Lead Generation: business-to-business lead generation in the provision of leads to customers to improve customer’s target marketing campaigns and services through different strategies. This includes generating leads through phone calls and email newsletter marketing to drive you to content, such as white papers and webinars, offered by Xpand Martech, Techresearchs, Martechintent and Globalmartek where upon your contact information will be shared with our customer.
  • Marketing to Customers: We may market to current and prospective customers and their employees who have indicated an interest in doing business with, or have previously conducted business with, Xpand Martech in order to further generate and promote our business. Such efforts include sending marketing emails or conducting phone calls to drive the purchase of advertising, Online Data licensing, lead generation and other business services offered by Xpand Martech.
  • IT Administration: administration of Xpand Martech information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
  • Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
  • Financial Management: general business and financial management purposes, including economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements
  • Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
  • Legal Proceedings: establishing, exercising and defending legal rights.
  • Legal Compliance: Subject to applicable law, we reserve the right to release information concerning any user of Services when we have grounds to believe that the user is in violation of our Terms of Use or other published guidelines or has engaged in (or we have grounds to believe is engaging in) any illegal activity, and to release information in response to court and governmental orders, other requests from government entities, civil subpoenas, discovery requests and otherwise as required by law or regulatory obligations. We also may release information about users when we believe in good faith that such release is in the interest of protecting the rights, property, safety or security of Xpand Martech, any of our users or the public, or to respond to an emergency.
  1. Direct Marketing

Summary – Direct Marketing

We may Process your User Information to contact you with information regarding services that may be of interest to you. You may unsubscribe for free or opt out of SMS messages at any time.

We may Process your User Information to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

  1. Cookies, Similar Technologies and Online Behavioral Advertising

Summary – Cookies, Similar Technologies and Online Behavioral Advertising

We may Process your User Information by placing or reading Cookies and similar technologies on the Services and Channels. For more information, please see our Cookie Policy. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to Other Information about you, including your User Information for the purposes of learning more about you so we can provide you with relevant content and advertising. We and our partners also use these technologies to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement to our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns.

Xpand Martech and/or certain third parties may collect information about you for online behavioral advertising purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms, and media channels. We use Online Data as well as other User Information to send you online behavioral ads. Online Data is aggregated with the Other Information and data we collect and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred. We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests.

Xpand Martech and its partners may use cookies and other tracking technologies to analyze trends, administer Services, track users movements around the Services and on third party sites, devices and applications, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services. To manage Flash cookies, please click here. Please see our Cookie Policy for more information, including a more in-depth explanation of what cookies are, the different types of cookies used on the Services, and how to change or delete them.

Tracking technologies on the Services may be deployed by Xpand Martech and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.

When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information, and/or to aggregate that information with other data we collect to use for some or all of the purposes outlined in this Privacy Policy.

We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or User Information and use the associated information related to aggregate content preferences to assist in our efforts to market services to you or the originating corporation(s). Various browsers may offer their own management tools for removing Local Storage.

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.

Xpand Martech and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.

Xpand Martech displays ads on both the Services and on the Channels. We may use Online Data as well as other User Information to send you OBA. For example, if you read an article about a particular subject on the Services, we may use cookies from a vendor to later serve you an advertisement for a particular product or service related to the viewed article. These third party vendors may connect information about pages you visit on the Services with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Services or on another Channel. Likewise, third party vendors may serve you advertisements when you visit the Services based on your interaction with the Services and other Channels.

Online Data is aggregated with the Other Information and data we collect as described in this Privacy Policy and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred based on (a) demographic or interest data and GeoIP Data, (b) the pages you view and links you click when viewing an email or using the Services and those of our partners, and/or (c) the search terms you enter when using certain search services. We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests. We store page views, clicks and search terms used for ad personalization targeting separately from your Personal Information.

  1. What is the Lawful Basis for Processing Personal Information

Summary – Lawful Basis for Processing User Information

We may Process your User Information where: you have given your consent; the Processing is necessary for a contract between you and us; the Processing is required by applicable law; the Processing is necessary to protect the vital interests of any individual; or where we have a valid legitimate interest in the Processing.

In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

  • Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
  • Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
  • Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
  • Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
  • Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

As described above, we have identified our lead generation services and how we market our business to our current and prospective customers as having a legitimate interest.

  1. What Information We Disclose to Third Parties

Summary – Disclosure of User Information to Third Parties

We may disclose your User Information to legal and regulatory authorities; our external advisors; parties who Process User Information on our behalf (“Processors”); any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on the Services.

We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:

  • legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
  • outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
  • third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 9;
  • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
  • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
  • any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
  • any relevant third party provider, where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
  • any sponsors of contests, competitions, sweepstakes and prize draws, or white papers, webcasts or other downloads, the registration data for such events is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events. For contests, competitions, sweepstakes and prize draws, please read the official rules or terms and conditions carefully before you submit your information; and
  • to third parties whose practices are not covered by this Privacy Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers).

For some of our Services, we may make some information, such as the name of our users, their mailing address, phone number, email address—and in certain circumstances their employer’s name, company size and other industry data—available on a rental or other basis (e.g., sale) to third party providers of goods and services, for example, when such information is provided in connection with webcasts, white papers or other sponsored downloads.

When you use a co-branded service (a service operated with a partner of   Xpand Martech ), or register or otherwise provide information on a co-branded site, you grant us permission to pass the collected information back to that partner, which may include third party service providers whose services are embedded into and/or appear within the Services;

With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Xpand Martech advises users of the possibility of such disclosure at the time they take the survey, Xpand Martech reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

Xpand Martech and some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.

We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.

We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from  Xpand Martech with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

  1. International Transfers of Information

Because of the international nature of our business, we may need to transfer your User Information within the Xpand Martech group of companies, and to third parties, as noted in Section 9 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

  1. Data Security

Summary – Data Security

We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

  1. Data Accuracy

Summary – Data Accuracy

We take every reasonable step to ensure that your User Information is kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

  1. Data Minimization

Summary – Data Minimization

We take every reasonable step to limit the volume of your User Information that we Process to what is necessary.

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

  1. Data Retention

Summary – Data Retention

We take every reasonable step to ensure that your User Information is only retained for as long as they are needed. Online Data related to OBA is kept by Xpand Martech for not more than 180 days after which it will expire, subject to certain conditions.

We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

Except as may be set forth in this Privacy Policy, Online Data related to OBA is retained by Xpand Martech for not more than 180 days after which it shall expire. However, the 180 day period may commence again if the same user subsequently visits or interacts with an ad, email, the Services or a Channel.

  1. What Can I Do to Control My Information?

Summary – What Can I Do to Control My Information?

You can directly take steps to change your preferences for newsletters and online behavioral advertising as outlined in this section.

If you are an EU resident, you may have certain rights including the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.

You may directly take steps to change your preferences as follows:

Access to Your Personal Information. Upon request  Xpand Martech will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or contacting us through our contact info. We will respond to your request within a reasonable timeframe.

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

Location Based Services. You may opt-out of having your Precise Location Data collected by Xpand Martech at any time by editing the appropriate setting on your mobile device (which is usually located in the Settings area of your device).

California Residents. In accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out in Section 17 below.

EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us using the DSAR Portal. If you are an EU resident and have any unresolved privacy concern, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

  1. Terms of Use

Summary – Terms of Use

For all Services, the  Xpand Martech Terms of Use will govern.

For more information concerning your use of the Services, please visit the  Xpand Martech Terms of Use. The  Xpand Martech Terms of Use is incorporated by reference into this Privacy Policy.

We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

  1. Contact Details

Summary – Contact Details

  • You may contact us at the addresses set out below or by emailing
  • Xpand Martech
  • contact@xpandmart.com

If you are an EU resident, you may contact our Data Protection Officer at contact@xpandmartech.com or submit GDPR related inquiries to our DSAR Portal.

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact: contact@xpandmartech.com

Summary – California Consumers

The California Consumer Privacy Act (“CCPA)  provides certain rights for California consumers.  If you are a consumer residing in California, the following additional terms apply to you.

  1. Right to Know About Information Collected, Disclosed or Sold

You have the right to request that we disclose what personal information we collect, use, disclose, and sell. To submit a verifiable request, please visit our DSAR Portal or email info@xpandmartech.com If you have an account with us, we will verify the request by confirming the email address used to make the request is the same as the email address on file for the account.  If you do not have an account with us, we will verify the request by sending an email to the email address used to make the request. We may ask for additional information reasonably related to the request to verify the request.

  1. Collection of Personal Information

The categories of California consumers’ Personal Information we may collect are listed above in Section 2 (“What Categories of Information We Process”).  In reference to Section 2, we may collect Personal Details, Demographic Information, Contact Details, Consent Records, Location Information, Purchase and Payment Details, Employer Details, Views and Opinions.  We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy. As detailed in Section 2, this may include, but is not limited to, information about your use of, visits to and interaction and engagement with the Services, content and ads on Channels, all of which may be aggregated; browsing history; and searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.

We may collect California consumers’ Personal Information from the sources listed in Section 4 (“How We Collect User Information”). As defined in Section 4, this may be: Data You Provide; Relationship Data; Data You Make Public; Service Data; Content and Advertising Information; Third Party Information; Speed test data if you run a Speed test by Ookla  We may obtain personal information from the following sources as defined in Section 2 (“What Categories of Information We Process”): GeoIP Data; ID; IDFA; IP address; ISP; SSID; IMSI; IMEI; Log files; Web Beacons; Pixel Tags; Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, and equivalents.

We use this data for the purposes listed above in Section 5 (“Purposes for which we may Process your Personal Information”) or for Direct Marketing as outlined in Section 6 (“Direct Marketing”).

  1. Disclosure or Sale of Personal Information

We may and may have disclosed or sold the categories of Personal Information listed in Section 9 (“What Information We Disclose to Third Parties”) for a business or commercial purpose.

We may and may have disclosed Personal Information to the following categories of third parties for a business purpose:

  • other entities within the Company group for a legitimate business purpose such as operating the Services and providing the Services to you;
  • third party Processors for the purpose of providing the Services to you;
  • third party providers where our Services use third party advertising, plugins or content;
  • third party providers to assist with the collection, storage and segmentation of Online Data.  These third party providers may collect User Information from our Services for their own purposes, including but not limited to, monitoring fraud around the web;
  • third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Xpand Martech with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser; and
  • third party vendors involved in the administration of contests, competitions, sweepstakes, prize draws, or webcasts.

We may have disclosed or sold Personal Information to the following categories of third parties for a business purpose or commercial purpose:

  • third party providers where our Services use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Services and Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
  • third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Xpand Martech with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser;
  • third parties such as advertisers who will use Online Data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture;
  • third party partners such as marketing and advertising companies and agencies, content publishers, retailers, third party providers of goods and services; or service providers whose services are embedded into and/or appear within the Services when you use a co-branded service (a service operated with a partner of Xpand Martech), or register or otherwise provide information on such co-branded site. This information is only passed on if and when you grant us permission to pass the collected information back to that third party;
  • Any sponsors of contests, competitions, sweepstakes and prize draws, or white papers, webcasts or other downloads, the registration data for such events is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy.
  • third party providers of goods and services on a rental or other basis for some of our Services when information (such as the name of our users, their mailing address, phone number, email address – and in certain circumstances their employer’s name, company size and other industry data) is provided in connection with webcasts, white papers or other sponsored downloads.

The Services are not intended for use by minors. We do not sell personal information of minors under 16 years of age without affirmative authorization.

  1. Right to Request Deletion of Personal Information

You have the right to request deletion of Personal Information collected or maintained by us.  To do so, please submit a request via DSAR Portal or by emailing info@xpandmartech.com  If submitting a request by email, we may ask for additional information to verify your request.

  1. Right to Opt-Out of the Sale of Personal Information

You have the right to opt-out of the sale of Personal Information by a business.  To do so, please submit a request via DSAR Portal or by emailing info@xpandmartech.com  If submitting a request by email, we may ask for additional information to verify your request.

  1. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive discriminatory treatment by the business for exercising your privacy rights conferred to you by the California Consumer Privacy Act.

  1. Authorized Agent

To make a request under the California Consumer Privacy Act on a consumer’s behalf, we require a signed authorization letter from the consumer to info@xpandmartech.com

  1. Contact for More Information

If you have any questions or concerns about our privacy policies and practices, you may contact us via DSAR Portal or info@xpandmartech.com

  1. Date Privacy Policy Last Updated

Our Privacy Policy was lasted updated as of the date indicated at the beginning of the policy.

  1. How this Privacy Policy May Change

We may change this Privacy Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we nf

Privacy Policy

Your privacy is important to us. It is Xpand Martech’s policy to respect your privacy regarding any information we may collect from you across our website, https://www.xpandmartech.com, and other sites we own and operate.

1. Information we collect

Device data

We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal information

We may ask for personal information, such as your:

  • Name
  • Email
  • Social media profiles
  • Date of birth
  • Phone/mobile number
  • Home/Mailing address
  • Work address

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

  • it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
  • we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to enable you to customize or personalize your experience of our website;
  • to enable you to access and use our website, associated applications, and associated social media platforms;
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms;
  • to run competitions and/or offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have; and
  • to consider your employment application.

4. Disclosure of personal information to third parties

We may disclose personal information to:

  • Third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • Our employees, contractors and/or related entities;
  • Sponsors or promoters of any competition we run;
  • Third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you; and
  • Third parties to collect and process data.

5. International transfers of personal information

The personal information we collect is stored and processed in India, where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

7. Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

9. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

10. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

We urge you to come back to this web page and review this Privacy Policy regularly so that you remain aware of the terms and conditions that apply to you.