1. How We Collect Personal Information
When we talk about
, we mean any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.
A. When we collect Personal Information
We collect Personal Information when you voluntarily provide it through our Services, or when you provide it to us through other means. The categories of Personal Information we collect depends on how you use our Services. For example, we may collect Personal Information when you:
contact us through email or other correspondence;
register for or request a service we provide or which we make available to you through our Services;
register an account on our Services;
upload content to our Services, including using the journal function or sharing cards; or
creating and uploading a deck for sale on our Services.
We also collect information about you from other sources. We may obtain this information from sources such as:
third party service providers, including Google analytics; and
publicly available sources.
B. What Personal Information we collect from you
your email address, if you choose to create an account on the Services;
your username on the Services;
your journal entries on our Services;
your created decks uploaded to our Services;
any other Personal Information that you choose to submit to us or upload to the Services.
When you interact with us or other users of the Services we collect certain information. This information may include:
information about how, when, and where you use our Services;
error logging, event recording and user experience data; and
the settings you use on our Services.
C. Information we collect through technological means
When you use our Services, we may collect information that is automatically sent to us by your computer and/or mobile device which runs our Site. This information may include your IP address. We may also collect other information, such as data about your usage of our Services. Additionally, we may also collect other technical and system log information from you, such as:
the type of device you’re using;
your operating system and version information;
the type of browser you’re using, and your browser settings;
mobile network information;
content you view on our Services;
your unique device identifier;
the full Uniform Resource Locator (URL) clickstream to, through, and from our Site, including date and time;
your system activity; and
software debug and crash information.
We use this information to improve our understanding of how users use our Services, and to improve our Services. The amount of information that is sent to us by technological means depends on your device and settings you use. Please refer to the instructions provided by your device if you want to learn more about what information it sends to Services you use, or how you may change or restrict this.
Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”).
We use all options that Google Analytics provides for maximising your privacy including instructing them to anonymise your IP address, transmitting data by an SSL connection only, and manually stripping out any personally identifiable information before transmitting to Google Analytics.
If you’d prefer to opt out of Google Analytics data collection, you can install the Google Analytics Opt-out Browser Add-on, which stops data transmission to Google Analytics.
2. How We Use and Disclose Information Collected from You
A. Our use of Personal Information
to deliver our Services to you;
to register your account on the Services;
to verify and authenticate your account information;
to provide you with information, products, or services that you request from us;
to send you informational or administrative communications;
to communicate with you and to enable other users to communicate with you;
to respond to your inquiries and provide you with customer support;
to increase the security and safety of our Services and users;
to notify you about changes or updates to the Services;
to send you marketing and advertising communications, in accordance with your choices and communications preferences;
to serve you relevant advertisements and content;
to perform analytics on our Services;
for any other purposes that are disclosed to you and to which you consent; and
for any purpose required by law.
B. Our disclosure of Personal Information
Generally, we do not disclose your Personal Information to third parties without your consent. However, in order to provide you with the Services, we may need to transfer your Personal Information to our subsidiaries, parent companies, employees, contractors, consultants, government agencies and regulators, and other parties who require such information to assist us with managing and administering our relationship with you, including:
third parties that provide services to us or on our behalf;
third parties that assist us in the provision of Services to you; and
third parties whose services we use to conduct our business.
Additionally, in order to provide you with the Services, we may need to transfer your Personal Information to third party technology companies for the purposes of processing and storing your Personal Information. Our business necessitates using: (a) cloud storage and hosting providers; (b) email services providers; and (c) payment processors. We consider these services, platforms, and applications to be integral to our delivery of the Services to you.
Under certain circumstances, we may disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We reserve the right to transfer Personal Information to a third party in the event that we merge with or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition. We also may disclose your Personal Information for any other purpose permitted by law or to which you consent.
We may disclose your Personal Information in the good faith belief that such action is necessary:
to protect and defend our rights or property;
to prevent or investigate possible wrongdoing in connection with our products or services;
to protect the personal safety of our customers or the public;
to comply with our legal obligations; or
to protect against legal liability.
3. How We Protect Personal Information
The security of your Personal Information is important to us. We are committed to ensuring your Personal Information is protected and will use industry-standard security measures, including Secure Socket Layer (SSL) technology, to do so. Personal Information may only be accessed by persons within our organization who require such access to provide you with the services indicated above. [NTD: confirm steps taken to protect personal information]
While we endeavour to keep your Personal Information safe, our collection, use, and disclosure of your Personal Information is not without risks. For example, our security safeguards may be compromised by viruses, hacking attempts, or physical break-ins. Consequently, we cannot guarantee the security of your Personal Information. If your Personal Information was wrongfully accessed, there is a risk that you may suffer a harm, such as identity or credit card theft or financial loss.
Please be careful whenever sending Personal Information to us via email. Email is generally not a secure means of transferring information. We therefore cannot guarantee that this information will not be lost or used in a fraudulent manner and we encourage the use of email encryption or other encrypted services to communicate with us.
4. Data Storage, Retention, and Deletion
The Personal Information we collect from you is stored in our servers located in the United States.
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
5. Processing and Transfer of Information
We may need to transfer your Personal Information to our service providers for processing. This processing supports our business. For example, we may transfer your Personal Information to our cloud hosting provider for storage and retention purposes. We ensure that these recipients of your Personal Information are contractually obligated to keep your Personal Information confidential, to use it only for the purposes for which we transfer it to them, and to process the Personal Information with standards at least as stringent as those set out in this policy.
Personal Information may be stored and processed in any country where we do business or our service providers do business. We may transfer your Personal Information to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. Officials (such as law enforcement or security authorities) in those other countries may be entitled to access your Personal Information By using any of our Services, or by sending us any Personal Information, you consent to such transfers.
6. Third Party Collection of Information
7. Personal Information of Children
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.
8. Access and Rectification
You have a right to challenge the accuracy and completeness of your Personal Information and to have it amended, as appropriate. You also have a right to request access to your Personal Information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal Personal Information about another individual, your request for access may be limited or denied.
To request access or to amend your Personal Information, please contact us using the contact information provided below.
9. Withdrawal of Consent
You may withdraw your consent to our collection, use, and disclosure of your Personal Information at any time, subject to legal and/or contractual restrictions and reasonable notice. Your withdrawal of consent to our collection, use and disclosure of your Personal Information may impact our ability to provide you with products and services and may impact your ability to use the Services. To withdraw consent, please contact us using the contact information provided below.
10. How to Contact Us