Z+O Innovations, LLC (“Z+O”, “us”, “we” or “our”) is committed to protecting the privacy and confidentiality of any Personal Information we may collect from our customers. Z+O has created this privacy policy (“Privacy Policy”) to advise you about our information practices, such as the types of information we collect and how we may use that information, and to inform you about your privacy rights and how the law protects you. We urge you to read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. By visiting any part of our Website (as defined below) or otherwise providing Z+O with Personal Information by any means, you accept and agree to the practices described in this Privacy Policy and your continued use of the Websites (following the posting of a revised privacy policy) means that you accept and agree to the terms of the revised privacy policy, so please check the policy periodically for updates.
Individuals in the European Union (“EU”) should be sure to read the important information provided below, in addition to the other provisions in this Privacy Policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
II. THE INFORMATION WE COLLECT ABOUT YOU
Personal Information or personal data means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data). We and our third-party service providers may collect, use, store and transfer different kinds of Personal Information about you that we have grouped together as follows:
IDENTITY INFORMATION includes name, username or similar identifier, title, date of birth, and gender.
- DEMOGRAPHIC INFORMATION includes zip code, age and/or income.
- CONTACT INFORMATION includes billing address, delivery address, email address and telephone numbers.
- TECHNICAL INFORMATION includes internet protocol (IP) address, your login data, browser type and version, time zone setting and geographical location, browser plug-in types and versions, operating system and platform and other technology or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet) (“Device Identifier”) for any computer, mobile phone, tablet or other device (any of which are referred to herein as a “Device”) used to access the Websites.
- PROFILE INFORMATION includes your username and password, purchases or orders made by you, your interests, preferences, product feedback, and survey responses.
- USAGE DATA includes information about how you use our Websites, products and services, including all of the areas within our Websites that you visit or use and the time of day you visited the Websites, among other information.
- MARKETING AND COMMUNICATIONS INFORMATION includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- LOCATION INFORMATION includes information about your location using a variety of technologies, such as GPS, IP address, and connected or nearby Wi-Fi networks.
- USER CONTENT INFORMATION includes text (including questions, comments, and suggestions), pictures, audio, videos, or other content (collectively, "User Content") you share by participating and posting content publicly in reviews, interactive features, or other communication functionality (“Community Features”).
We also collect, use and share AGGREGATED INFORMATION such as statistical or demographic information for any purpose. Aggregated Information may be derived from your Personal Information but is not considered Personal Information in law as this information does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information that will be used in accordance with this Privacy Policy.
We do not collect (i) FINANCIAL INFORMATION, such as credit card account numbers, nor (ii) any SPECIAL CATEGORIES of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
III. HOW WE COLLECT YOUR PERSONAL INFORMATION
We use different methods to collect information from and about you including through:
- DIRECT INTERACTIONS. You may give us your Identity, Demographic, Contact, Profile, or Marketing and Communications Information by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes Personal Information you provide when you: create an account on our Websites; subscribe to emails or newsletters; request services or other information; enter a competition, promotion or survey; or give us feedback about products, services, or the Websites.
AUTOMATED TECHNOLOGIES OR INTERACTIONS. As you navigate through the Websites, we may automatically collect Technical, Usage, and Location Information about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, pixel tags, embedded scripts and other similar technologies. [We may also receive Technical Information about you if you visit other websites employing our cookies.]
- COOKIES- Cookies are small data files that a website sends to your Device while you are viewing the website that are stored on the Device. Cookies can be used for many purposes, including to monitor use of websites, to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, to speed up your searches and purchases and to recognize you when you return to our Websites and/or store your user name and password so you do not have to re-enter it each time you visit the Websites. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you choose to disable cookies on your Device, some features of the Websites or our content may not function properly.
- PIXEL TAG– Pixel Tags (also referred to as clear GIFs, 1x1 GIFs Web beacons, or Web bugs) are small graphic images or other web programming code that may be included on the Websites and in our e-mail messages. In contrast to Cookies, which are stored on a user’s Device, Pixel Tags are embedded invisibly in web pages. Pixel Tags may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a pixel tag. Pixel Tags or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Websites, to monitor how users navigate the Websites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
- EMBEDDED SCRIPTS- Embedded scripts are programming code designed to collect information about your interactions with the Websites, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a third party service provider, and is active only while you are connected to the Websites.
- FLASH LSOS – When we post videos, third parties may use local shared objects, known as “flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, please visit: HTTP://WWW.MACROMEDIA.COM/SUPPORT/DOCUMENTATION/EN/FLASHPLAYER/HELP/SETTINGS_MANAGER07.HTML
- COMMUNITY FEATURES. The Websites may provide you the opportunity to participate and post User Content publicly through reviews, surveys, interactive features, or other communication functionality (“Community Features”). We may provide functionality for you to submit or post User Content through Community Features, by linking the Websites to a third party service, or otherwise. Please note that certain information, such as your name, may be publicly displayed on the Websites along with your User Content. User Content consisting of uploaded files may contain metadata, which may contain Personal Information or other information about or relating to you. You may wish to remove metadata from your files before transmitting such files to Z+O. NOTE THAT ANYTHING YOU POST THROUGH COMMUNITY FEATURES IS PUBLIC – OTHERS WILL HAVE ACCESS TO YOUR USER CONTENT AND MAY USE IT OR SHARE IT WITH THIRD PARTIES. IF YOU CHOOSE TO VOLUNTARILY DISCLOSE PERSONAL INFORMATION, THAT INFORMATION WILL BE CONSIDERED PUBLIC INFORMATION AND THE PROTECTIONS OF THIS PRIVACY POLICY WILL NOT APPLY. IF YOU SUBMIT USER CONTENT, IT MAY BE PUBLISHED ONLINE OR OFFLINE AT ANY TIME. IN ADDITION, WE MAY USE YOUR USER CONTENT AND ANY EXCERPT FROM YOUR USER CONTENT IN CONNECTION WITH OUR ADVERTISING, MARKETING, PUBLICITY AND PROMOTIONAL ACTIVITIES.
- THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES. We may receive Personal Information about you from various third parties. For example, if you are on another website and you opt-in to receive information from us, the other website will forward your Contact Information and other information to us so that we may contact you as requested. We also may supplement the information we collect with outside records from third parties in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Websites. In those cases, we will apply this Privacy Policy to the combined information. Examples of third party sources include:
- Technical Information from the following parties: analytics providers; advertising networks; and search information.
- Contact Information from providers of technical, payment and delivery services.
- Identity and Contact Information from publicly available sources.
- INFORMATION PROVIDED FROM OTHER USERS. If you decide to invite a third party to create an account and/or purchase our merchandise, we will collect the Identity and Contact Information you provide (e.g., name and e-mail address) for you and the third party in order to send a message to the third party and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to collect such information and contact the third party as described in the foregoing sentence. You or the third party may contact us at privacy@ZOHemp.com to request the removal of this information from our database.
Certain functionality on the Websites may permit interactions that you initiate between the Websites and a third party website or service (“THIRD PARTY INTERACTIONS”). Examples of Third Party Interactions may include technology that enables you to “like” or “share” content from the Websites on or to other websites or services; to transmit content to the Websites from your account on a third party website or service; to otherwise connect the Websites to a third party website or service, such as through an application programming interface (API) made available by Z+O or a third party; or for users to register for an account and login through social networking sites such as Facebook and Google (each an “SNS”). By registering or logging in through a SNS, you are allowing the Websites to access your information and you are agreeing to the SNS’s Terms of Use and Privacy Policy in your use of such services. We may receive information from the SNS to make it easier for you to create an account with us. Any information that we collect from your SNS account may depend on the privacy settings you have with that SNS, so please consult the SNS’s privacy and data practices.
If you choose to use Third Party Interactions, information you post or provide access to may be publicly displayed on the Websites or by the provider of the Social Feature that you use. Similarly, if you post information on a third party platform that references the Websites (e.g., by mentioning one of the Websites or using a hashtag associated with one of the Websites in a tweet or status update), your post may be published on our Websites in accordance with the terms of the third party website or service. Also, both Z+O and the third party may have access to certain information about you and your use of the Websites and the third party website or service. In addition, we may receive information about you in connection with other users’ use of Third Party Interactions (e.g., we may learn that you are a “friend” or “connection” of the third party or receive other information about you that the other user enables us to receive).
The information we collect in connection with Third Party Interactions is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website or service.
V. THIRD PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
Z+O works with certain third parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Websites, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Websites and the effectiveness of our advertisements. These third parties may use Device Identifier and Usage Data to compile reports on user activity. For example, if you clicked on one of our advertisements that led you to one of the Websites, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and pixel tags) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. Cookies and pixel tags, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics.
These third parties may also transfer Device Identifier and Usage Data to other third parties where required to do so by law, or where such third parties process analytics information on their behalf. Each of these third party’s ability to use and share Device Identifier and Usage Data is restricted by their respective Terms of Use and Privacy Policy. By using our Websites, you consent to the processing of data about you by these third parties in the manner and for the purposes set out above. For a full list of third party analytics services, please contact us at privacy@ZOHemp.com.
We may share Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising.
For additional information regarding targeted advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:
- NAI Opt-Out Tool (for website users): http://www.networkadvertising.org/managing/opt_out.asp
- DAA Consumer Choice (for website users): http://www.aboutads.info/choices/
- DAA AppChoices (for mobile app users): http://youradchoices.com/appchoices
Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Websites and elsewhere online. Some third parties may collect Personal Information about your online activities over time and across different websites.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Websites currently do not respond to or alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
VI. HOW WE USE YOUR PERSONAL INFORMATION
We may use the information we collect about you, including Personal Information and Usage Data: to provide you with our products and services and related customer service; to process your registration and account creation with the Websites, including verifying your contact information is active and valid; to identify you as a user in our system; to provide you with information, products or services that you have requested or agreed to receive; to provide improved administration of our Websites and services; to process transactions you initiate, process payments and provide accurate billing and shipping; to send you administrative e-mail notifications, such as order confirmations, order status updates, security, or support and maintenance advisories; to bill you for Z+O products or services respond to your inquiries related to employment opportunities or other requests; send newsletters, surveys, offers, and other promotional materials related to our services and for other marketing purposes of Z+O; to market our products/services, including recommending products/services that might be of interest to you; to improve our Websites, product and service offerings; to present our Websites and its contents in a suitable and effective manner for you and for your computer; to customize and tailor your experience on the Websites, for example, by displaying content that we think you might be interested; to improve the quality of experience when you interact with our Site and Services for internal business purposes; for compliance fraud prevention and safety, including enforcing our terms of service and this Privacy Policy, protecting our rights privacy, safety, or property and/or that of you or others, and protecting against, investigating or deterring fraudulent, harmful, unauthorized, unethical or illegal activity; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us; to notify you about changes to our service; to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; to contact you with regard to your use of the Websites and, in our discretion, changes to the Websites policies or functionality; and to perform other functions as described at the time of collection, with your consent, or as further described in this Privacy Policy.
In addition to the above, we may use anonymous data to analyze request and usage patterns so that we may enhance the content of our services and improve navigation on the Websites. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.
- CHROME: https://support.google.com/chrome/answer/95647?hl=en;
- EDGE: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;
- FIREFOX: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;
- INTERNET EXPLORER: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies;
- OPERA: http://www.opera.com/help/tutorials/security/cookies/; and
- SAFARI: https://support.apple.com/kb/PH21411.
VII. DISCLOSURES OF YOUR PERSONAL INFORMATION
We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.
We may disclose the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, or in the following circumstances:
VIII. YOUR CHOICES
You have several choices regarding the use of information on our Websites and services:
IX. DATA SECURITY
Z+O uses commercially reasonable security measures to safeguard the Personal Information we collect from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, please note that no system can be completely secure and Z+O does not ensure or warrant the security of any information we collect. You use our Websites and provide us with your information at your own risk.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
X. USERS OUTSIDE OF THE UNITED STATES AND INTERNATIONAL TRANSFERS
The Websites are hosted and operated in the United States and Z+O and its third party service providers and partners operate in the United States and other jurisdictions. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States and other countries. By using the Websites, or providing us with any information, you acknowledge and consent to this transfer, processing and storage of your information in countries where the privacy laws may be less stringent than those in the country where you reside or are a citizen.
XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information regarding Z+O’s disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties (and in some cases, affiliates) for their direct marketing purposes.
If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request to the following email address: privacy@ZOHemp.com. You must put the statement "Your California Privacy Rights" in the subject field of your e-mail. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
XII. QUESTIONS
If you have any questions or concerns regarding our privacy policy or practices, please feel free to contact us via email at privacy@ZOHemp.com.
XIII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION
- Where we need to perform obligations relating to a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include those related to conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal or regulatory obligation.
PURPOSE/ACTIVITY
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TYPE OF INFORMATION
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LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
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To register you as a new customer or user
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(a) Identity (b) Contact (c) Profile
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Performance of a contract with you and/or taking steps, at your request, to enter such a contract
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To process and deliver products and services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us
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(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications
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(a) Performance of a contract with you and/or taking steps, at your request, to enter such a contract (b) Necessary for our legitimate interests (to recover debts due to us)
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To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking you to leave a review or take a survey
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(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
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(a) Performance of a contract with you and/or taking steps, at your request, to enter such a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
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To enable you to participate in sweepstakes, contests and promotional activities or complete a survey
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(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
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(a) Performance of a contract with you and/or taking steps, at your request, to enter such a contract (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
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To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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(a) Identity (b) Contact (c) Technical (d) Usage (e) Location |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
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(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Location
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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(a) Technical (b) Usage
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)
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To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
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Necessary for our legitimate interests (to develop our products/services and grow our business)
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To allow participation in Community Features |
(a) Identity (b) Profile (b ) User Content |
(a) Performance of a contract with you and/or taking steps, at your request, to enter such a contract (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business, to allow user interaction on the Websites) |
- REQUEST ACCESS to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- REQUEST CORRECTION of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- REQUEST ERASURE of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- OBJECT TO PROCESSING of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
- REQUEST RESTRICTION OF PROCESSING of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- REQUEST THE TRANSFER of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- WITHDRAW CONSENT at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
REVISED: DECEMBER 1, 2018