Last updated on August 10, 2020
While you may visit our Website or otherwise use the Services without telling us who you are or revealing any Personal Data [Client to confirm], please note that our server logs capture information regarding your operating system, browser type, IP (Internet Protocol), URL clickstream through, and from our Website, including date and time.
We apply the following means to automatically collect data (including Personal Data) from you:
We use pixels from LinkedIn and Facebook to track visitors to our site and serve them ads using customary retargeting methods.
We also use standard browser Cookies, which are stored on your browser application, computer or other device. These Cookies do not store any Personal Data and are used only to verify that the user is logged in. They are deleted when you close your browser.
By using the Website and/or otherwise engaging any of the Services, you understand that we may place Cookies on your computer, including analytical cookies, in accordance with the terms of this Cookies Policy, for such purposes described under our Privacy Notice.
If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at email@example.com.
Last Revised: August 11, 2020
Please read this Privacy Notice carefully to understand our policies and practices regarding your data (including Personal Data, as prescribed below) and how we will treat it.
We will collect and process your Personal Data as described in this Privacy Notice. Where applicable, we will obtain your opt-in consent for such purpose.
However, with respect to Personal Data which we collect for certain purposes reflecting our legitimate interests and/or non-Personal Data, your browsing of the Website and/or use of the Services, will be deemed as your consent, which you may opt-out from by deleting your Account. Thus, if you do not agree with our policies and practices, do not access, register with or use any of the Services (and if applicable, delete your Account).
This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of the Services after we make changes to this Privacy Notice is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates. However, where such changes require your opt-in consent in our opinion, we will act to obtain such consent.
In the event that you make available any personal data other than your own within the course of the Services (including by any communication means) to us and/or any other entity, then you will be solely responsible for obtaining all consents and approvals from the respective data subjects, and further for having them acknowledge this Privacy Notice.
What Data we Collect and How we Use It
Upon registration with the Services, a User profile is developed to further customize your experience. We collect personally identifiable information (the "Personal Data") you actively enter onto our online forms during registration or while using the Services as well as certain non-personal or de-identified data, as described below.
We collect the following types of data about you:
Data you provide us directly: When you register on, or otherwise use the Services, we may collect the following Personal Data you provide via forms, surveys, applications or other online fields: [NTD- list must be exhaustive for GDPR purposes]
First and Last Name
Date of Birth
Address and Zip Code
Telephone, fax and mobile numbers
User account photo
Billing information and other financial information
Communications or correspondence related to our Services, which might contain Personal Data
We use this data (including Personal Data) to operate, maintain, and provide to you the features and functionality of the Services, , and for compliance with applicable law (including any potential legal dispute) .
We will also use this data to send you a text message or an email to confirm your registration with us.
Data we may receive from third parties: In some cases, we may receive data about you from third party(ies) such as social media channels or third party(ies) who used our Services to invite you. For example, if you access our Site or Services through a third-party connection or log-in like Facebook Connect, by “following,” “liking,” adding the PRoPS application, linking your account to the Service, etc., that third party may pass certain data about your use of its service to PRoPS. This data could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any data that you have permitted the third party to share with us, and any data you have made public in connection with that service. In addition, we may collect and use certain kinds of publicly-available data about you from social media sites, including number of followers, number of likes or number of posts. If you allow us access to your friends list, your friends' user IDs, and your connection to those friends, we may use and store this data to make your experience more social, and to allow you to invite your friends to use our Services as well as provide you with updates if and when your friends join PRoPS. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services. You may also unlink your third party account from the Services by adjusting your settings on the third party service. If you unlink your third party account, we will remove the data collected about you in connection with that service.
Inviting a friend to use PRoPS through use of the Service: If you choose to allow PRoPS to access your contacts, and you message those contacts through use of our Services, PRoPS may invite such third party contact to the Services by email or text message — but we do not require that you import your contacts list to the Service, and we do not retain the data contained in your contacts list. You understand that by inviting a friend to PRoPS, you are directly sending a text or email from your account and that we are not storing your contact list. In addition, you understand and agree that normal carrier charges may apply to communications sent from your phone. Since this invitation is coming directly from you, we do not have access to or control this communication. [NTD- This might be an issue in terms of local laws of other jurisdictions in terms of anti-spam rules]
Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies, beacons, and pixels installed on such device, and the activity (clicks and other interactions) of users of our Website and/or other Services.
We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use browse our Website. The use of such technical and device data also helps us and our partners to deliver contextual or otherwise more effective advertisements and content; to optimize our ad management and our users' viewing experience, and to improve the overall user experience and functionality of our Website.
Please refer to our Cookies Policy to better learn what type of data (including Personal Data) we collect via these means, and the manner in which we use such data.
Marketing and service communications: We use the data we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers, without sharing your Personal Data with third parties. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your data to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related e-mails.
Sharing of Your Data
We will not rent or sell your data to third parties outside PRoPS and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted below:
Who we may share your data with: We may share your data with third-party service providers for the purpose of providing the Services to you. This sharing is necessary to provide you access and use of the Services and such service providers will be given limited access to your data as is reasonably necessary to deliver the Services and will not sell or otherwise impermissibly disclose your data. In some cases we may collect or share your data with third-party business partners for the purpose of providing you a more customized experience on our Services or to serve marketing material of such business partner. If we engage in such collection or use, we will provide you the opportunity to opt-out of such sharing with business partners at the time of collection or use.
The current third party service providers that have access to your Personal Data are as follows:
Facebook and Linkedin for pixel and retargeting purposes/ Google for website performance tracking. Campaign Monitor for list building.
What happens in the event of a change of control: We may buy or sell/divest/transfer the company (including any equity interests in the company), or any combination of its products, services, assets and/or businesses. The data you provide to us or we collect from you may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such data in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.
Sharing certain non-personal data we collect about you: We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
Storage and Processing: Your data collected through the Services may be stored and processed in the United States or any other country in which PRoPS or its subsidiaries, affiliates or service providers maintain facilities. While privacy laws may vary between jurisdictions, ProPS has taken reasonable steps to ensure that your Personal Data is treated in a secure and lawful manner and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in other applicable jurisdictions. Thus, while PRoPS may transfer information that we collect about you, including Personal Data, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world, if you are located in the European Union, please note that ProPS will only transfer your Personal Data to a country and jurisdiction that has at least the same data protection laws as your jurisdiction and/or as otherwise permitted under the GDPR.
Keeping your data safe: PRoPS cares about the security of your data, and uses commercially reasonable safeguards to preserve the integrity and security of all data collected through the Service. To protect your privacy and security, we take reasonable steps (such as two-step authentication) to verify your identity before granting you initial access to your account. You are responsible for any use of the Services on your account, whether by you or a third party, as well as for controlling access to your email communications from PRoPS, at all times. However, PRoPS cannot ensure or warrant the security of any data you transmit to PRoPS or guarantee that data on the Services may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the PRoPS Service, such as social networks. PRoPS is not responsible for the functionality or security measures of any third party. [NTD- under GDPR requirements, adequate security means should be applied, depending on the type of personal data collected / stored. If Props collects sensitive data such as billing information etc., then it should verify, for example, that 2 step authentication is actually considered adequate in this case]
Compromise of data: In the event that any data under our control is compromised as a result of a breach of security, PRoPS will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose data may have been compromised and take other steps, in accordance with any applicable laws and regulations.
How long we keep your personal data: Generally, we retain your Personal Data for a period of [___] months from date of the date in which the respective Personal Data was collected. However, (i) we retain your Personal Data pertaining to your name, Account, contact information (including email), so long as your account is not deactivated; (ii) we may retain your Personal Data (including such Personal Data specified un subsection (i) above), for a longer period for accounting, archival, audit and legal purposes (i.e., as required by laws applicable to our record and bookkeeping, and in order to have proof and evidence concerning our relationship or any claims related thereto, should any legal issues arise). [NTD- GDPR best practice is to have a data retention policy which describes what type of personal data is retained for which period, and the reasoning for such decision]
Your Choices about Your Data
You control your account information and settings: You may update your account data and email-communication preferences at any time by accessing your account and changing your profile settings. You can also stop receiving promotional email communications from us, if any, by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service-related communications (e.g., account verification, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account data, you can contact us directly at firstname.lastname@example.org.
Your Rights Regarding Your Personal Data Under GDPR and Applicable Law
You may have certain rights regarding the manner of collection, processing, and usage of your Personal Data pursuant to applicable privacy laws (such as the EU GDPR). Under the GDPR (to the extent it applies to you) you may be eligible for the following rights:
Please note that the above list contains a summary of the main rights you may have under the GDPR. Under no circumstances shall the above be deemed as an exhaustive list.
PRoPS does not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register as Users. The Services and its content are not directed at children under the age of 16. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at email@example.com.
Links to Other Web Sites and Services
How to Contact Us
If you have any questions about this Privacy Notice or the Service, or in the event that you wish to exercise your rights with respect to your Personal Data, please contact us at firstname.lastname@example.org.