Last updated on 25 August, 2021
1. Types of Personal Information That Might Be Collected
When you visit our Website, the following types of *Personally Identifiable Information (as such term is explained at the end of this Section) about you may be collected:
- your IP address;
- your operating system and browser software used to access our Website;
- other information, as will be explained in Section 4 (With Whom We Share Information) below;
- in the event you contact us by email, we may keep a record of that correspondence; such record may include, apart from your email address, the Personally Identifiable Information that you will include in the communication.
Such data are collected by Our Partners (as such term is explained in Section 4).
If you wish to register on our Website in order to receive our subscription-based services, we will ask you to provide the following data:
- your email address;
- your gender;
- your date of birth.
In addition, when subscribing for any of the services offered on our Website you will be requested to identify your display name and choose your profile image which may be an avatar or a photo. The display name is what will be displayed next to your comments on our Website. We strongly encourage you not to use your real-life name and/or surname as your display name.
We never share with third parties any of the data supplied by you as part of subscription-based services/registration.
2. Ways Personal Information Might Be Used
Use of Personal Data by Us. We collect and use your Personally Identifiable Information for the following legitimate business purposes of LAVENDER:
- to carry out general data analysis and to administer our Website and affiliated sites;
- to generate statistics and measure web traffic and popularity of specific areas of our Website;
- to identify usage trends and expand our business activities;
- to build higher quality and develop more useful services by performing statistical analyses of the collective characteristics and behavior of our users
- to improve or modify our Website, develop new services and functionality;
- to comply with applicable legal requirements, legal process and relevant industry standards, and satisfy requests by governmental and supervisory authorities;
- to identify and prevent fraud.
Additionally, if you choose to register on our Website in order to receive our subscription-based services, your Personally Identifiable Information will be used in order to communicate with you.
If, at any time, you decide to unsubscribe from receiving future emails, detailed unsubscribe instructions will be displayed at the bottom of each email.
Use of Personal Data by Our Partners. Our Partners (as such term is explained in Section 4, With Whom We Share Information) may be collecting and using your Personally Identifiable Information to tailor the content that advertisers display to you, including building relevant data segments based on what you click and view and when or how many times you have viewed it; for these purposes, they use the information collected by technologies, such as pixel tags or cookies, to improve the services provided by third-party advertising companies, which include Google. The list of Google partners can be viewed at partners.
3. What You Agree to by Using Our Website
Before using Personally Identifiable Information for a purpose other than any of the purposes set out in the preceding Section 2 (Ways Personal Information Might Be Used) we will request your explicit consent.
4. With Whom We Share Information
Except as set forth in this Policy or as explicitly agreed by you, we will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Policy, we may disclose and otherwise use Personally Identifiable Information as described below.
Our Partners. We allow third parties, including carefully selected ad networks and business partners (referred to as «Our Partners»), to display advertising on our Website. Our Partners may, for instance, collect, use and share your information to make or help us make predictions about your interests, and may provide you with offers, promotional materials, and advertisements. In addition, Our Partners may be collecting certain information related to your PC, laptop, mobile phone or other device attributes and traffic/session information. Our Website permits Our Partners to collect your Personally Identifiable Information to provide personalized advertising to you. Our Partners are leading digital performance-based advertising groups which put great effort in making sure that your personal information is safe and used properly.
Service Providers. Your information may be collected by entities that provide services to us, including companies that deliver web analytics, data processing, data enhancement and customer insights, advertising, email distribution, and other services.
Other Parties (when required by law or as necessary to protect our services). We may disclose your information (including Personally Identifiable Information) to other parties in order to:
- protect our legal rights or property, the legal rights or property of our affiliates, and sites or services we work with;
- protect the rights, safety and security of our users, ourselves, or any other person or entity;
- prevent fraud (or for risk management purposes);
- comply with applicable legal requirements, legal process or request for cooperation by a governmental or supervisory authority, whether or not legally required. For example, we may be required to disclose your information to meet national security or law enforcement requirements.
Other Parties (in connection with transfer of assets). If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer (or due diligence related to such a transaction), or in the unlikely event of bankruptcy, we may transfer your Personally Identifiable Information as part of that transaction.
Use for Analytical and Ad Serving Purposes. We use standard tools common within the industry, such as Google Analytics, to collect information about use of our Website. These tools collect information such as how often you visit our Website and what other sites you visited prior to reaching our Website. We use the information we obtain from analytical tools for the purposes of improving our Website. The analytical tools collect only the IP address assigned to your computer or other device and your browser settings as of the moment you visit our Website, rather than your name or other identifying information.
Finally, our Website relies on common industry tools Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. These tools help us understand the composition of viewers of our Website in terms of gender, age and interests. We need this information in order to understand what types of creative content we need to develop to suit the interests of different demographic and interest groups. In addition, Our Partners may need this information to develop marketing content. You may, at any time, opt out of Google Analytics tracking, including Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting, by installing the Google Analytics Opt-Out Browser Add-On. You may also opt out of ad serving through Google’s opt-out page.
You can opt out of ads personalization using Google’s Ads Settings by following the instructions contained on the following resource of Google — Google Ads Settings. If you choose to opt out of ads personalization, you will no longer receive personalized advertising.
5. Cross-Border Transfer of Information
We generally maintain centralized servers and systems in Europe and may maintain servers and systems elsewhere. These servers and systems are managed by us or on our behalf, or by our affiliates located in Europe.
In the event of transfer and processing of your Personally Identifiable Information outside the EEA for the purposes described above, we will ascertain that the information receives the same level of protection as if it remained within the EEA, including when entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU-US Privacy Shield.
6. How We Keep Your Information Secure
We use commercially reasonable physical, electronic, and procedural safeguards to protect your Personally Identifiable Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with requirements of applicable laws.
7. Use of ‘Cookies’
8. Use of Information for Personal Advertising
The information collected by Our Partners is used to analyze trends, understand user activities and gather demographic information to enable, manage and develop their personalized ads and related services. Our Partners may share such information with their affiliates. To do this, Our Partners use technologies such as cookies and web beacons to collect information about your interaction with our Website and third-party websites. This type of information does not identify you personally and, typically, is aggregated with other data to create segments —groups of users and general interest categories that are inferred based on a range of factors (for example, «sports fan»). Our Partners use this information to form a more accurate picture of the interests of the audiences with which they interact — including you — so that their ads are more relevant to those interests.
In addition, Our Partners may use the information collected from these types of cookie or similar technologies for a variety of other purposes, including:
- in conjunction with advertising that appears on other third-party websites;
- to measure the effectiveness of web-based and email advertisements;
- for reporting website traffic, statistics, advertisement data and other interaction with ads and the websites on which they are served.
Our Partners retain your information in accordance with their legitimate business purposes for processing. Thereafter, the information is removed, archived for restricted legitimate interests, or anonymized. Non-identifying information may be kept without time and use limitations.
9. Retention of Personal Information
If you reside or are located in the EEA, your Personally Identifiable Information will be stored for no longer than necessary for the purpose for which the Personally Identifiable Information was collected. The length of time Personally Identifiable Information is retained depends on the purpose for which such information was collected and/or as required to comply with applicable laws and establish, exercise or defend our legal rights.
10. Your Legal Rights
You have certain rights in relation to your Personally Identifiable Information. Depending on the jurisdiction, you have the right to request that we:
- provide access to any Personally Identifiable Information we, or Our Partners, hold about you;
- update any Personally Identifiable Information which is out of date or incorrect;
- delete any Personally Identifiable Information which we, or Our Partners, are holding about you;
- object to certain means of processing of Personally Identifiable Information (e.g., opt-out from marketing communications);
- restrict the way in which we process your Personally Identifiable Information;
- provide your Personally Identifiable Information to a third-party service provider;
- provide you with a copy of any Personally Identifiable Information which we hold about you.
11. Children’s Privacy
No part of our Website is directed to children or minors under the age of 18, and we do not knowingly collect Personally Identifiable Information from anyone that we know is under 18 years of age. If you are under 16 years of age (unless a lower age threshold between 13 and 16 applies in your country), then please do not use or access this Website, or ask your parents for permission before using our Website or sending any information about yourself to anyone over the Internet. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Website without verifiable parental consent upon learning of the existence of such Personally Identifiable Information.
12. Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (CCPA), California residents are entitled to request to know more details about the categories or specific pieces of personal information we collect, use, disclose and “sell” (under CCPA “sale” is broadly defined and it may include allowing third parties access to information like cookies, IP address, geolocation — which all allow us to personalize your Website and mobile application experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and mobile applications), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
In the past 12 month we collected, disclosed and “sold” the following personal information to our business partners for the purposes described below:
|What type of the personal information||Collected||How do we get the personal information||We may use, disclose and “sell” the personal information||To whom|
|A. Identifiers, including cookies, IP address, email address, account name||Yes||From you||To process your requests for products/services and/or information, to communicate with you, to improve our Services, for the administration and protection of our business, and to comply with applicable law, regulations, and legal and regulatory processes.||Service providers, our business partners.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||No|
|C. Protected classification characteristics under California or federal law.||No|
|D. Commercial information.||No|
|E. Biometric information||No|
|F. Internet or other similar network activity.||Yes||From you and your device||To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites||Service providers, our business partners.|
|G. Geolocation data.||Yes||From you||To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites||Service providers, our business partners.|
|H. Sensory data.||No|
|I. Professional or employment-related information||No|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||No|
|K. Inferences drawn from other personal information.||Yes||From you and your device||To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites||Service providers, our business partners.|
|Other Identifiers and Internet Activity Information||Yes||From you and your device||Service providers, our business partners.|
If you are California resident you can submit your request for access or deletion of any of your personal information that we collected from you and retained, subject to certain exceptions, via this email email@example.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. You can also designate an authorized agent to exercise these rights on your behalf. You may only make a verifiable consumer request for access or deletion twice within a 12-month period.
You may also request to opt-out from the “sale” of your personal data. CCPA broadly defines “sale” and it may include allowing third parties access to information like cookies, IP address, geolocation — which all allow us to personalize your Website and mobile application experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and mobile applications.
If you would like to opt-out of our use of your personal information for such purposes, you may do so by contacting us at firstname.lastname@example.org. You have the right not to be discriminated against for exercising any of your CCPA rights.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
13. Questions, Suggestions and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us at firstname.lastname@example.org.
If you reside or are located within the EEA, we may assist with all queries regarding our processing of Personally Identifiable Information. We request that you please attempt to resolve any issues related to your Personally Identifiable Information with us first. If you reside or are located within the EEA, you may also make a complaint to the supervisory authority for data protection in your country of residence (such as, for instance, the UK Information Commissioner’s Office for the UK) or seek a remedy through local courts if you believe that your rights have been breached.
14. External Links
Our Website may display links to websites of third-party content providers, other than Our Partners. We do not disclose your Personally Identifiable Information to third parties, other than Our Partners, without obtaining your consent specifically permitting such disclosure. We do not endorse and are not responsible for the privacy practices and content of such third parties. We encourage you to review their privacy policies to understand how they collect and process your Personally Identifiable Information.
15. Changes to This Policy
We revise and evaluate this Policy periodically in light of changing business practices, technology and legal requirements. As a result, this Policy will be updated from time to time. Any such changes will be posted on this page. Any change, update, or modification will be effective immediately upon posting on our Website.
16. Contact Us
If you have any questions or concerns regarding this Policy, our privacy practices, or to exercise your rights, please contact us by email at email@example.com.