(Last Updated: September 16, 2020)
If you are a resident of California and the CCPA applies to you, please review our Privacy Notice for California Residents to find out more about your privacy rights in your jurisdiction.
2. Policy Updates
3. The Types of Data We Collect and Our Lawful Bases for Processing Such Data
When you access our Website or use our Services we may collect the following types of data from you:
Non-Personal Data: Non-personal data means non-identifiable, aggregated data that is mainly technical data transmitted by your device and use of the Services. This data cannot be used to identify an individual (“Non-Personal Data”).
Personal Data: Personal data means individually identifiable information, mainly information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).
Our lawful bases for processing Personal Data under the GDPR are as follows:
When you sign up for our Services either as a Partner or a Client, we process your Personal Data in order to perform our contract with you;
When we have a legitimate interest to process your Personal Data, such as for direct marketing purposes or when we process your internet protocol address ("IP") when you access our Website; or
When you give us your consent to do so.
You are not required by law to provide us with any of your information. You are able to choose not to provide us with some of your Personal Data; however, this may prevent you from being able to use certain aspects of our Services. In the event that we combine Personal Data with Non-Personal Data, the combined data will be treated as Personal Data for as long as it remains combined.
Publicly Available Partner Information
Data We Collect From Visitors
Type of Data & How We Use It?
When you contact us for support or other inquiries, either through the online form available on the Website or via email, you will be requested to provide us with your name and email address.
We will use this information solely in order to respond to your inquiries and provide you with the support or the information you requested.
When a Visitor visits our Website, we (either directly or through our third-party service providers as further explained below) may process their IP.
We use this information with your consent to: (i) operate, provide, maintain, protect, manage, customize and improve our Website and Services and the way in which we offer them; (ii) enhance your experience with the Services; and (iii) audit and track usage statistics and traffic flow.
We also collect certain technical Non-Personal Data (as explained above) that relates to your use of the Website.
We use these technical data in order to operate and manage our Website.
Data We Collect From Clients
Type of Data & How We Use It?
You will be required to open an account with us in order to use our Services. You may need to provide us with certain information such as your full name, email address, phone number and company name in order to create an account with us.
We will use this information in order to perform our contract with you, provide you with the Services you requested, and assign your account. We will use your email address and phone number in order to send you any necessary information related to the Services and our business engagement (e.g., to notify you regarding any updates to our Services, send applicable invoices, and on occasion, additional information related to the Services) as well as in order to verify your identity.
4. Direct Marketing
We may send our Clients or Partners emails or other messages about us or regarding our Services. You can remove your Personal Data from our mailing list and stop receiving promotional communications from us by following the unsubscribe link located at the bottom of the communication or by emailing us at: email@example.com. Please note however, that if you are a Partner and you choose to unsubscribe from our mailing list, we reserve the right to send you service-related communications, including service announcements and administrative messages relating to your account, without offering you the opportunity to opt out of receiving them unless you terminate and delete your account. If you wish to delete your account, please contact us at: firstname.lastname@example.org. Please note that, if we do delete your account, we will not be able to delete certain information that we are required to retain in accordance with applicable law or otherwise required for the legitimate purposes of our business.
5. How We Collect Information
We may collect your information in one or more of the following ways:
We use the following cookies on our Website:
Type of Cookie: Google Analytics
Purpose: This cookie is used in order to track and analyze the use of our Services, for internal purposes, such as to know how many Visitors access our Website.
You may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of the browser that you are using. The following are some links which you may find helpful: Google Chrome ; Firefox ; Internet Explorer; Safari; Edge; Opera
In the event, that you have any additional complaints about your privacy rights, please contact our Data Protection Officer at: dpo!internationalrenewals.com or our privacy team at: email@example.com and we will be happy to assist you.
7. Disclosure of Data
We do not share your Personal Data with third parties except as specifically mentioned herein:
Third Party service providers – we may disclose your Personal Data to third parties that perform services on our behalf (e.g. tracking, servers, service functionality and support, marketing, etc.) These entities are prohibited from using your Personal Data for any purposes other than providing us with the requested services and they may be located in different jurisdictions;
Legal Requirement – we may disclose or share your Personal Data, solely to the extent needed to comply with any applicable law, regulation, legal process or governmental request (i.e., to comply with a court injunction, etc.) or for the purpose of collaborating with law enforcement agencies;
Third Party Rights – we may share your Personal Data, solely to the extent needed to prevent harm to the rights (including intellectual property rights and other legal rights), property or safety of us, our users, yourself or any other third party.
Policy Enforcement – we may share your Personal Data, solely to the extent needed in order to enforce our policies including investigations of potential violations thereof, to establish or exercise our rights to defend against legal claims or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
Affiliated Companies and Corporate Transaction– we may share your Personal Data with a parent company, subsidiaries, joint ventures, or other companies under common control with the Company ("Affiliated Companies") solely if and when applicable or necessary. In addition, we may share information, in the event of a corporate transaction (e.g. sale, merger, consolidation, etc.), provided however, that our Affiliated Companies or acquiring company will be subject to the obligations detailed herein with respect to your Personal Data;
We may store Non-Personal Data and Personal Data on our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Services, as explained above. This information may be collected, processed and analyzed by us and transferred in a combined and aggregated manner (i.e., your information will be immediately combined with the information of other users) to third parties.
8. Data Retention
We retain the information we collect as long as is necessary for the purposes set forth above, in accordance with applicable laws, or until an individual requests that we delete his or her Personal Data. We may, at our sole discretion, delete or amend information retained on our systems, without providing any prior notice to you, once we deem it is no longer necessary for such purposes.
9. Securing and Transferring Data
The security of our Website, Services and your Personal Data is extremely important to us and we take it very seriously. We use industry standard procedures and policies to ensure the safety of our Visitors', Partners' and Clients' Personal Data and to prevent any unauthorized use of it. We implemented technical, physical and administrative security measures to protect the Personal Data, including, without limitation, by using industry standard encryption (SSL) methods. In addition, we limit access to your information on our servers. The data collected by us is stored on AWS's data servers. Please see AWS's security policy available here: https://aws.amazon.com/security/ for more information regarding the data security provided by AWS. Please visit the following link to learn more regarding our security measures.
10. User Rights
We provide you with the ability to exercise certain choices, rights and controls in connection with your Personal Data, according to applicable data protection and privacy laws.
Privacy laws differ from jurisdiction to jurisdiction, each of which may provide you with different rights regarding your Personal Data. The following are some of the rights that you may be able to exercise depending on the applicable data protection laws that apply to you.
The right to access your Personal Data - you have the right to request confirmation that we process your Personal Data, and under some circumstances, be provided with a copy of your Personal Data that we process.
The right to be forgotten - you have the right to require the erasure of certain Personal Data, if specific conditions are satisfied (if the Personal Data is no longer needed for the original purpose that it was collected for and there is no new lawful basis for continued processing); if you exercised your right to withdraw consent (if applicable), or to object to the processing and we have no overriding grounds for continuing to process the Personal Data; the Personal Data is processed unlawfully; or the erasure of the Personal Data is necessary in order to comply with applicable legislation. Please note, that this right is not absolute. We may not accept a request under certain circumstances, for example if we need to retain the applicable Personal Data in order to comply with our legal obligations or defend against legal claims, etc.
The right to object to the processing of your Personal Data - you have the right to object to our processing of your Personal Data, in the event the legal basis for processing is our legitimate interests. Notwithstanding the above, we will be permitted to continue the processing of such Personal Data if our legitimate interests override your rights, or when the processing is necessary to establish, exercise or defend a legal claim, etc.
The right to restrict processing - you may be entitled to limit the purposes for which we process your Personal Data. This right is applicable when: the accuracy of the Personal Data is contested; the processing of the Personal Data is unlawful and you request restriction instead of erasure; the Personal Data is no longer needed for the original purpose it was collected, however, it is still required to establish, exercise or defend legal rights; or there are overriding grounds in the context of an erasure request;
Rectification - you have the right to require an entity that is processing your Personal Data to update your Personal Data that is not correct;
Data Portability - you have the right to have your Personal Data "ported" to a third-party;
File a complaint - You may also be entitled to file a complaint with the appropriate supervisory authority in connection with any concerns you may have with regards to your privacy
Please fill out our privacy rights request form. If you wish to submit a request to exercise any of the above rights and send it to our Data Protection Officer ("DPO") at: firstname.lastname@example.org]. Please note that we may require additional information from you in order to verify your identity and locate your information. This may take some time, subject to applicable law. If we require more time, we will inform you in writing of the reason for the required extension and the length of time the extension will be. Additionally, you have the right to contact your local data protection authority, at any time. If we cannot fulfill a request we will explain our reasons why we cannot do so in the response to such request. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Please note that the data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you.
11. Data Transfer
12. Children’s Privacy
13. Contact Us
If you have any questions or comments about this Policy, or any concerns with respect to how your privacy or Personal Data is handled, please contact us at:
The International Renewals Group
44 Court St. Suite 1217 PMB 94689
Brooklyn, NY 11201