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Last updated: May15th, 2018
We collect information about visitors to our Sites, employees of our customers and users of our customer’s social media pages / properties. Such information is collected about you, including personal information, from the following sources:
Information We Collect Directly from You: The type of information that we collect directly from you varies based on your interaction with our Site and our Service. We collect information directly from you when you register an account with us, use the “Sign In with Facebook” or similar button on our website, liaise with us on a customer service issue, complete an application or other forms on the Site and/or software. We also collect information that you send us via any medium, including, but not limited to email, telephone, as well as social media interactions like your social media handle.
We also may collect any personal data concerning you or any third party that you have chosen to make accessible to general public, e.g. through Facebook APIs or YouTube APIs, on various social networks or anywhere else on the internet.
For purposes of analysis and improvement of our Services, our servers may automatically record information when you visit our website or use some of our Services, including URL, IP address, Browser type and language; and Date and time of your request.
Information We Receive from Customers: We may receive information from customers in order to provide our Service. Such information may include a user’s social media handle, username, profile, biography and messages or communications with our customers. We collect information from individuals employed by our customers such as their contact information in order to provide our Service.
When you visit our Site or use our Service, we collect certain information automatically from your device.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location. If you are a client of Le Guide Noir, we may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked, or Service, including content accessed.
We may place a "cookie" on the hard drive of the device that you use to access the Service. Cookies are text files that are saved on the hard drive of your device by means of your browser, enabling us to recognize your browser for purposes such as automatically authenticating you and logging you into the Service, saving your preferences and directing relevant content to you. Most of the currently available browsers give you the option of managing cookies by, for example, disabling them entirely, accepting them individually, and deleting saved cookies from your hard drive. We would like to remind you that if you completely disable cookies on your browser, you might not be able to use some features of the Service.
We may also place tracking pixels in the Service. A tracking pixel is a transparent graphic image that is placed on a web page and, in combination with a cookie, allows for the collection of information regarding the use of the web page that contains the tracking pixel.
We use API keys of third-party software to authenticate the user to us.
Google Analytics is an element of the Service. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the website, the Internet Protocol address, and the type of operating system used in the devices used to access the Service. By using a browser plugin http://www.google.com/ads/preferences/plugin provided by Google, you can opt out of Google Analytics.
LGN processes your personal information for the following purposes:
- Operate and improve the Site and Service;
- Provide users or customers with the Service and other products and services that a user or customer may request or that a user or customer has expressed interest in;
- Facilitate subscription processing, reviews and analysis;
- Evaluate user interest and needs in order to improve the Service and make available other offers, products or services;
- Evaluate the types of offers, products or services we make available to users or customers and potential users or customers;
- Monitor use of the Service;
- For verification purposes (such as determining free trial eligibility);
- Provide customer support;
- Communicate and provide additional information that may be of interest to users through email or other means, such as special offers, announcements, and marketing materials;
- Send you reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
We may send you various newsletters or communications which may include, for instance, details about the Services and their features, including newsletters containing special offers in which you may be interested. We may also send you invitation to events that we organize such as Engage. For these purposes, we may share your contact details with our vendors or business partners who provide services or functions on our behalf, including event organization, marketing, distribution of surveys or sweepstakes programs, payment processing, customer service, or public relations. These third-party vendors have access to and may collect information only as needed to perform their functions on our behalf and are not permitted to share or use the information for any other purpose.
Your marketing communication preferences may be changed at any time by following the instructions below:
If you would like to unsubscribe from an email sent to you, follow the ‘unsubscribe’ link and/or instructions placed at the bottom of the email.
Alternatively, you can contact us using the details in the “Contact Us” section below to change your marketing communication preferences.
Please note that we may occasionally send you important information (including via email) about our Services that you are using or have used including changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations.
These important Service communications are not affected by your marketing communication preferences.
We may disclose your information, including personal information, to the following categories of recipients:
We do not share personal information with third parties for their own marketing purposes.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In order to manage our operations, we may cooperate with third parties and transfer selected data to such third parties. Currently, third parties to whom data relating to you and your use of the Services may be transferred, and the purposes of such transfers include:
You have the following data protection rights:
If you wish to access, correct, update or request erasure of your personal information, you can do so at any time by emailing us at firstname.lastname@example.org . Note that if you submit a request to delete your personal information, this may prohibit you using the Site and/or Service.
In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us at email@example.com. Note that if you submit such a request, this may prohibit you using the Site and/or Service.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing emails we send you.
Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we process your personal information solely on behalf of a customer, we may be legally required to forward your request directly to our customer and social media business partners for their review / handling.
Our Site and/or Service utilizes various appropriate technical and organizational security measures, which include, but are not limited to, network and host security controls (e.g., firewalls, intrusion detection systems, etc.), data encryption (both at rest and during transmission), and operating procedures that are designed to protect your personal information. You should protect your user ID and password and NOT share it with anyone. Additionally, enabling two-step verification, where available, is also recommended. If you believe your user ID and password have been compromised or you have trouble changing your user ID/password on the Site or Service, please contact our technical support department (firstname.lastname@example.org).
We have implemented and will maintain appropriate technical and organizational measures, internal controls, and information security routines in accordance with good industry practice while keeping in mind the state of technological development in order to protect your data against accidental loss, destruction, alteration, unauthorized disclosure or access or unlawful destruction. Such measures may include, without limitation, taking reasonable steps to ensure the reliability of employees having access to your data and providing for limited access rights and access controls; authentication; personnel training; regular back up; data recovery and incident management procedures; restrictions on storing, printing and disposal of personal data; software protection of devices on which personal data are stored; etc. Upon request, we will provide further details about the measures implemented by us and our data service providers.
Data collected from you may be transferred to, and stored and processed in, the European Union or any other country in which Le Guide Noir, its affiliates, subcontractors, suppliers or other third party vendors maintain facilities. While we reserve the right to change our business partners and /or data locations, when we transfer any personal data to the USA or any other country outside the EU or EEA in which LGN, its affiliates, subcontractors, suppliers or vendors maintain facilities, we will implement such appropriate legal mechanism as are required by EU law to ensure an adequate level of personal data protection by such third parties receiving your personal data (for example, European Commission’s Standard Contractual Clauses).
In addition to our current vendors listed in Section 3, the production data from our Services are currently transferred to and stored and processed by Amazon Web Services, Inc., 410 Terry Avenue, Seattle, WA 98109 (“AWS”). LGN has signed the controller-to-processor Standard Contractual Clauses approved by the European Commission (2010/87/EU) to ensure regulatory compliance for data transfers from Europe to the USA. The specific AWS Data Processing Addendum incorporating these model clauses has been approved and validated on EU level by Article 29 Working Party in 2015 as ensuring an adequate level of protection.
See https://d0.awsstatic.com/whitepapers/compliance/AWS_EU_Data_Protection_Whitepaper_EN.pdf and http://www.cnpd.public.lu/en/actualites/international/2015/03/AWS/index.html for more details.
Your data may be accessed by LGN’s’ subsidiaries and affiliates for the purposes of providing the Services to you. Currently, LGN’s subsidiaries, affiliates and activity hubs are described here.
In some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our servers are located in the E.U., and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
The Service is not intended for users younger than sixteen (16) years of age. We do not collect any personal data from children under sixteen (16) years of age.
In compliance with the General Data Protection Regulation (GDPR), we commit to resolve complaints about your privacy and our collection or use of your personal information We will work to resolve your issue and will respond within thirty (30) days of receipt.
If your complaint cannot be resolved through the above channel, you may contact the Spanish Protection Data Agency located on Jorge Juan 6, 28001 Madrid with the following telephone number 91-266-3517.