EU Privacy Rights Addendum
Table of contents
If you reside in the European Union (“EU”) or the European Economic Area (“EEA”), the European Union General Data Protection Regulation (“GDPR”) will apply to how we collect and process your personal information. If you reside in the United Kingdom, the United Kingdom General Data Protection Regulation (“UK GDPR”) will apply to how we collect and process your personal information. Under the GDPR and UK GDPR, EU and UK residents have certain rights with respect to their personal information. You can make the following choices regarding your personal information:
- Access to your personal information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. We will provide this information in a portable format if required.
- Changes to your personal information. We rely on you to update and correct your personal information. Our website(s) allow you to modify or delete your account profile. If our Website or App does not permit you to update or correct certain information, you may contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
- Objections/Restriction to your personal information. You have the right to object to how personal data is processed in relation to public interest/official authority and our legitimate interests as well as direct marketing purposes – including profiling under both. You also have the right to request that processing of your personal information be restricted where its accuracy or lawfulness is contested, you need it in response to legal claims or in relation to verification as to whether legitimate interests for processing exist (resulting from objection made under Art 21(1).
- Deletion of your personal information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law. Where certain grounds apply, the law authorizes you to make a request that your personal information be deleted and triggers our corresponding obligation to comply, unless exceptions apply.
- Move, copy or export personal data. This is known as the Right of Portability. You have the right to request that your personal data be forwarded to a third party.
- Provision/Revocation of Consent. You have the right to provide or decline consent to the processing of personal information. If you’ve already provided consent, you also have the right to revoke it. This will not impact the legality of processing prior to revocation. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you with services. In some cases, we may deny your request to revoke consent if the law permits or requires us to do so – such as when we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.
We are committed to resolving valid complaints about your privacy and our collection or use of your personal information. For questions or complaints regarding our data use practices or this Privacy Notice, please contact us as provided below. Should you remain unsatisfied with our response to your complaint, you have the right to contact your local data protection authority.
Please note that your rights are not absolute, meaning that in some circumstances, exceptions exist under applicable law. The law may provide exemptions from requests involving your personal data. For example, in order to provide our Services to you, deleting your personal information may prevent you from accessing or using it.
You may exercise these rights here. We will respond to any such request in a timely manner as specified by the GDPR. If we need more time to fulfill your request, we will let you know in advance. We will not exceed the legally specified time limit under any circumstance.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or other account information. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
- A completed, signed Authorized Agent Designation form indicating that you have the authorization to act on the consumer’s behalf.
If we do not receive the information, the request will be denied.