Updated as of July 7th, 2020
This Application collects some Personal Data from its Users.
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Owner and Data Controller
Eric Resnick, ProfileHelper
Owner contact email: firstname.lastname@example.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name; last name; company name; website.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, User database management, Access to third-party accounts, Displaying content from external platforms, Hosting and backend infrastructure, Managing contacts and sending messages, Contacting the User, Registration and authentication and Remarketing and behavioral targeting.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
- Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Stripe account access (Stripe Inc)
This service allows this Application to connect with the User’s account on Stripe, provided by Stripe, Inc.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies; Usage Data.
- Contacting the User
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data collected: email address; first name.
- Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.
Personal Data collected: email address; Usage Data.
- Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
- Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data collected: email address.
- Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data collected: company name; email address; first name; last name; website.
- Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
- User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
- Personal Data collected through sources other than the User
The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data.Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
- Keeping you signed in
- Understanding how you use our website
What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
- Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Additional information about Data collection and processing
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
The means by which the Personal Data of the User is collected and processed.
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
ProfileHelper California Privacy Notice
Scope of Disclosures
This California Privacy Notice (the “CA Notice”) supplements the information contained above in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).
This CA Notice describes how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA).
Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.
Personal Information Disclosures
When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This CA Notice does not apply to personal information we collect when we are acting as a service provider to process information on behalf of our clients to whom we provide legal services.
For the purposes of this CA Notice, personal information does not include:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.
- Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Information relating to our job applicants, employees, contractors and other ProfileHelper personnel.
Collection and Use of Personal Information
We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the Personal Information We Collect About You and How We Use It section in our Privacy Notice.
In the last 12 months, we have collected the following categories of personal information, from the sources and for the purposes stated below.
|Category of Personal Information Collected||Collected||Categories of Sources|
|Identifiers, such as your name, address, phone number, email address, or other similar identifiers.||✅||
· Directly from you
· Our business partners and affiliates
· Third parties you direct to share information with us
|Commercial Information, such as your use of our services.||✅||· Directly from you|
|Protected Classification Characteristics, such as age, gender, religion, and disability information.||✅||· Directly from you|
|Internet/Network Information, such as your IP address, or browser or device information.||✅||· Your browser or device|
|Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address.||✅||· Your browser or device|
|Sensory Information, such as pictures of you.||✅||· Directly from you|
|Professional/Employment Information, such as your employing entity, business unit, manager and management reporting structure, job title, function and the nature of your duties and responsibilities.||✅||
· Directly from you
· Third parties you direct to share information with us
|Other Personal Information, such as information you provide to us when you register for or attend an event organized or hosted by us, including your preferences or education information, information you permit us to see when interacting with us through social media, or comments and opinions you provide to us such as when you post on message boards, blogs or complete an online form.||✅||
· Directly from you
· Our business partners and affiliates
· Third parties you direct to share information with us
· Information generated from your online browsing and usage activity
|Inferences,including information generated from your use of the websites reflecting predictions about your interests and preferences.||✅||
· Your browser or Device
· Information generated from your online browsing and usage activity
Purposes for Collecting Personal Information
We may collect, use or disclose personal information about you for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry.
- To deal with enquiries and complaints made by or about you relating to our services.
- To communicate with you, including through email to provide you updates, alerts, news and mailings relating to seminars or events that we think may be of interest to you.
- To operate, maintain, and provide to you the features and functionality of our services.
- To market to you, including through email.
- To send you statements and invoices in relation to any agreement between us to provide you with any part of the services.
- To better understand the demographics of our users.
- To personalize your experience and to deliver custom content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, or on other devices you may use.
- To recognize you and remember your information when you return to our websites and services.
- To help maintain the safety, security, and integrity of our services, technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our services.
- To assist you in sharing content from our services, or your experiences on our services, with your friends, followers or contacts on a social network.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Disclosure of Personal Information
In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the table above, to third parties for a business purpose. We do not sell personal information to third parties.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
|The Right to Know||
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
· The specific pieces of personal information we have collected about you;
· The categories of personal information we have collected about you;
· The categories of sources of the personal information;
· The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
· The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
· The business or commercial purposes for collecting or, if applicable, selling the personal information.
|The Right to Request Deletion||You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.|
|The Right to Opt Out of Personal Information Sales||You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
|The Right to Non-Discrimination||You have the right not to receive discriminatory treatment for exercising these rights.
However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
|“Shine the Light”||California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).|
How to Exercise Your California Consumer Rights
To Exercise Your Right to Know or Right to Deletion
To exercise your Right to Know and/or your Right to Deletion, please submit a request by:
- Email your request to email@example.com with the subject line “California Rights Request,” or
- Calling 888-447-7634
We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt-Out of Personal Information Sales
We do not sell personal information to third parties.
Minors Under Age 16
We do not and will not “sell” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
California’s “Shine the Light” Law
In addition to the rights described above, California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to firstname.lastname@example.org. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email address specified in this section.
Updates to This CA Notice
We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.
If you have any questions or requests in connection with this CA Notice or other privacy-related matters, please send an email to email@example.com.