Effective from Year: 2018-19
HOW TO CONTACT US
You may contact WebClues Global directly if you have any question regarding the Services or our privacy practices.
INFORMATION WE COLLECT
We provide various informational, educational, and entertainment features as part of the Services. To operate these features, we collect information from our Users. The types of information that WebClues Global collects depends on the purpose for which each User chooses to use the Services.
We use the information we collect from Users to provide more meaningful editorial and advertising content and to offer relevant products and services, as well as to maintain, protect and improve Users’ overall experience.
- When a User subscribes to our services we may collect the name, email address and postal service address of the subscriber and, if a gift subscription, of the purchaser.
- When a User submits a request for support, WebClues Global may collect the following types of information: name, telephone number, email address and other information that the User chooses to give us to respond to the support request.
- When you connect with us through a social media platform, we may, depending on your privacy settings, receive some information from your social media account.
When you use the Services, we use collect information about which features you’ve used, how you’ve used them and the devices you use to access the Services. Depending on the settings of a User’s computer or mobile device (“Device“),WebClues Global also automatically collects: Internet Protocol (IP) address; MAC address; Device make, model and operating system version; mobile network information; internet service provider; browser type and language; country and time zone in which the Device is located; and metadata stored on the Device. This information is collected through cookies and other tracking tools. WebClues Global may supplement the information you provide to us with information from other sources. All of this information is treated as personal information when it directly or indirectly identifies an individual User.
HOW WE USE INFORMATION
We use information to operate the Services, including:
To administer your account and provide the Services to you
- Create and manage your account
- Provide you with customer support and respond to your requests
- Communicate with you about the Services
To inform you about offers and events
- Develop, display and track content and advertising tailored to your interests on the Services and other websites
- Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
- The information collected in conjunction with events may also be used for the marketing of additional services and events by us and/or our promotional partners and sponsors beyond the contest, sweepstakes and/or special event. Depending on the event, Users either grant their approval on how their information is used before it is collected (‘opt-in’), or choose to deny use of their information for additional purposes (‘opt-out’).
To improve the Services and develop new ones
- Administer focus groups and surveys
- Conduct research and analysis of Users’ behavior to improve the Services
- Develop new features and services.
To prevent, detect and fight fraud or other illegal or unauthorized activities
- Address ongoing or alleged fraud or other misbehavior on or though the Services
- Analyze data to better understand and design countermeasures against fraud
- Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
- Comply with legal requirements
- Assist law enforcement
- Enforce or exercise our rights, for example our Terms of Service
- Legitimate interests: We may use your information where we have legitimate interests to do so. For example, we analyze our Users’ behavior to improve the Services, to prevent and detect fraud and misuse.
- Consent: From time to time, we may ask for your consent to use your information. You may withdraw your consent at any time by contacting us using the contact information provided above.
USE AND COLLECTION OF INFORMATION BY OPERATIONAL PROVIDERS
HOW WE SHARE INFORMATION
- With our operational providers and partners
- With our affiliates
We share your information with our affiliates to help us with technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, better understanding how the Services are used and Users’ behavior to improve the Services, securing our data and systems, fighting against spam, abuse, fraud and intellectual property infringement.
- For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
- When required by law
Applicable law may require us and our service providers to disclose your information if: (i) reasonably necessary to comply with a legal process, such as a court order, subpoena or search warrant, government investigation or other legal requirements; or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).
- To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
- With your consent or at your request
We may ask for your consent to share your information with third parties. When we do, we will make clear why we want to share the information.
We may collect and provide aggregate information about our Users (such as how many persons visited a particular page or activity or the likes and dislikes of our Users) to our advertisers, sponsors, promotional partners and affiliates but this aggregated information does not include personal information about any individual User.
USE AND COLLECTION OF INFORMATION BY ADVERTISERS AND SPONSORS; THIRD PARTY COOKIES AND TRACKING TOOLS
We use third-party advertising companies to serve ads on the Websites. These advertising companies may collect and use information (not including your name, address, e-mail address or telephone number) about your visits to the Websites and other websites not owned and operated by us, and may also combine this information with other data about your purchases and interests from other online and offline sources, in order to provide advertisements about goods and services that may interest you (as inferred from your online activity).
We also share usage information about Users of the Websites with these companies for the purpose of managing and targeting advertisements and for market research analysis on the Websites and other websites. For these purposes, we and our third party advertising companies may note some of the pages you visit on the Websites through the use of GIFs. In the course of serving advertisements to the Websites, our third party advertisers may place or recognize a unique ‘cookie’ on your computer. The Websites may post banner ads and other forms of advertisements, and/or links to the websites of affiliate entities or of advertisers or sponsors who are companies that are not owned or operated by us, or our affiliates or subsidiaries. These entities may independently solicit and collect personal information, or send their own cookies and/or clear GIFs to our Users. The data collected is used in order to provide advertisements about goods and services that may be of interest to Users of the Websites and other interactive media and may be used to keep track of user response to each advertisement. We also work with third-party data analytics and online targeting companies. Some of these companies may use non-personal information (not including your name, address, email address or telephone number) about your visits to the Websites and other websites in order to provide data and targeting recommendations based on which we may provide advertisements about goods and services of interest to you.
Many of the third-party companies we work with are members of the Network Advertising Initiative (NAI), a cooperative on online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices. The NAI has developed a tool that allows consumers to opt out of targeted advertising delivered by NAI members’ ad networks.
Following are the names and websites of some of the other companies who may set cookies on the Websites to serve or present the ads that appear on the Websites and to conduct research about the advertisements. You may learn about opting out of their targeted advertising programs by going to their respective websites.
HOW WE PROTECT AND RETAIN INFORMATION
We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your personal information to those employees who need to know that information to service your account or perform their job functions.
Although we takes precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your personal data is at your own risk and we expect that you will use appropriate security measures to protect your personal information.
You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.
If you believe that your account or information is no longer secure, please notify us immediately at privacy [at] WebClues Global.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Websites);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
- Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).
CROSS BORDER DATA TRANSFERS
Sharing of information sometimes involves cross-border data transfers to or from the United States of America and other jurisdictions. For example, where the Services are available to Users in the European Economic Area (“EEA”), personal information is transferred to the United States. We use the EU-US and Swiss-US Privacy Shield and standard contractual clauses approved by the European Commission to validate transfers of EEA residents’ personal information from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal information of EEA residents to protect the privacy and security of the transferred personal information.
YOUR CHOICES ABOUT YOUR INFORMATION
If you would like to review, correct, update, suppress, restrict or delete personal information (including Personal Data as defined in the PRIVACY SHIELD section below) that you have previously provided to us, or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (if this right to data portability is provided to you by law).
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. For your protection, we only fulfill requests for the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
LINKS TO OTHER WEBSITES AND SERVICES
Privacy Shield Principles
WebClues Global commits to processing Personal Data in accordance with the Privacy Shield Principles as follows:
Prior to collecting Personal Data WebClues Global notifies EU Users about the categories of Personal Data that WebClues Global collects and the purposes for collection and use of their Personal Data. WebClues Global will only process Personal Data in ways that are compatible with the purpose for which WebClues Global collected it or for purposes later authorized.
- Accountability for Onward Transfer
If WebClues Global transfers Personal Data to a third party, WebClues Global takes reasonable and appropriate steps to ensure that each third party transferee processes Personal Data transferred in a manner consistent with WebClues Global obligations under the Privacy Shield Principles. WebClues Global will ensure that each transfer is consistent with any notice provided to EU Users and any consent they have given.
- Data Integrity and Purpose Limitation
WebClues Global takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete and current. WebClues Global adheres to the Privacy Shield Principles for as long as it retains Personal Data in identifiable form. WebClues Global takes reasonable and appropriate measures to comply with the requirement under the Privacy Shield to retain Personal Data in identifiable form only for as long as it serves a purpose of processing.