Last Updated: July 31, 2018
1. Our Privacy Principles
We are committed to recognizing and respecting your privacy rights by keeping you informed and processing and protecting your personal data in compliance with applicable law.
Effective July 31, 2018, if you are from the European Economic Area (“ EEA”), our processing of your personal data will comply with the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”).
2. Information that We Collect from You
Account Data You Directly and Voluntarily Provide to Us
We may collect and process some or all of the following information you make available to us if you register, download or use the Services, such as your:
Other Registration Information
Customer Support or Technical Information you provide when you contact us with questions about your use of the Services
User Profile Data
We may also offer you the option to create a user profile that may be visible to other users of the Services. If you are a registered user you may also be able to adjust your account settings through your user account. We note that, even if you adjust your settings so that your user profile remains private, we will still be able to access and view the information you provide as part of your user profile.
Public Data You Post through the Services
If you post information on public areas of the Services, that data may be collected and used by us, other users of the Services, and the public generally, such as reviews, comments, and user content. We strongly recommend that you do not post any information through the Services that allows strangers to identify or locate you or that you otherwise do not want to share with the public.
Usage Data We Automatically Collect from You
In addition to the information you provide to us, the Services may collect and process additional data automatically, this data may include your:
Device Registration Data (for example, the type of mobile device you use, your mobile device’s unique device or advertising ID, IP address, operating system and browser type),
Device Settings (for example, your language preference)
Information about how you use the Services (for example, how many times you use the Services each day)
Requested and Referring URLs
Location Data collected through your Device (including, for example, precise location data such as GPS and WiFi information)
3. How We Use Your Information
Improving the Services, Providing Support, and Communicating With You
We and our service providers may use the data you provide or that is collected through the Services to operate and improve the Services, our other sites, applications, products and services, to contact you from time to time to provide you with important information and notices relating to the Services, and to communicate with you about marketing promotions.
Advertising and Third Party Content and Links
For information about how tracking works for online advertising purposes you can visit http://www.aboutads.info/choices orhttp:///www.aboutads.info/appchoices . We do not have access to or control over cookies, pixels or web beacons that third-party websites or partners may use. We are not responsible for the privacy practices or the content of these third-party websites. You are encouraged to review the privacy policies of the different websites that you visit.
We may also work with third party analytics companies to help us understand how the Services are being used, such as data collection, reporting, ad response measurement, website and mobile application analytics, and to assist with delivery of relevant marketing messages and advertisements.
We may use Google Analytics, an analytics service provided by Google or other third-party analytics services providers (“Analytics Services”) to collect information about your use of the Services. These Analytics Services may collect information about the content you view and your system information and geographic information. The information generated by the Analytics Services about your use of the Services will be transmitted to and stored by the Analytics Services. The information collected by the Analytics Services allows us to analyze your use of the Services.
We encourage you to review your device and Services settings to ensure they are consistent with your preferences, including with respect to the collection and use of information. You may be able to stop further collection of certain data by the Services by updating your applicable device settings, or you may uninstall the Services. In addition, you may choose not to share your location details by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider/carrier or device manufacturer.
Purchases and Payment Processors
Promotions, Sweepstakes, and Contests
If you wish to unsubscribe from receiving marketing communications from us by email, please follow the instructions contained in each email you receive from us describing how you can unsubscribe from receiving further marketing communications from us. If you are a registered user you may also be able to adjust your email settings by logging in to your account and adjusting your account settings.
Social Media and Sharing
The Services may use social networking or “share functionality” or may contain links to third-party social media sites or applications that are not owned or controlled by us. We also may allow you to use social media sites or applications to leverage your existing social media site or application accounts to access features of the Services. Your use of these features may result in the collection or sharing of information about you by these sites or applications, depending on the feature.
We have no control over, and assume no responsibility for, any share functionality or the content, privacy policies, or practices of any third-party site or application. We encourage you to review the privacy policies and settings on the social media sites or applications with which you interact to make sure you understand the information that may be collected, used, and shared by those sites. You are subject to the policies of those third parties when and where applicable.
4. How We Share Your Information
We may share the information you provide or that we collect in some circumstances as follows:
We may share your information with advertisers, third-party advertising networks and analytics companies who may use it to deliver targeted advertisements to you on the Services or third-party websites or advertisers. Similarly, these advertisers may share information with us about you that they have independently gathered or acquired. We may also share encrypted versions of information we have collected in order to enable our advertising partners to perform data analysis or for advertising-related use.
With Our Company Affiliates
We may share your information with members of the ITWIDL corporate family in order to provide joint content and services (like registration, transactions and customer support), or to improve your experience with the Services, products and other services.
With Our Partner Programs
If you are directed to the Services through a third party, we may share certain information back with that third party, which may include information such as name, email and value of purchase depending on the type of relationship or Services utilized.
For Marketing Campaigns
From time to time we may disclose certain information (name, mailing address and non-sensitive transactional information such as your purchase history, amounts paid and products ordered) to marketing companies for trade or rental purposes. If you prefer to opt-out of the use of your personal information by marketing companies for trade or rental purposes, please let us know at legal@Itwidl.com.
With Our Service Providers
We may share your information with our service providers who work on our behalf. For example, these service providers may handle payment or credit card processing, data management, customer data pooling or aggregating, feature administration, email distribution, market research, information analysis, and promotions management. These service providers will only have access to the information needed to perform these limited functions on our behalf.
As Required By Law or to Protect Rights and to Comply with Our Policies
Business Transfers or Bankruptcy
5. Your Access and Control of Your Information
We acknowledge your right to access and control your personal data.
Accessing, Correcting or Deleting Your Information
To request access to or correction of your personal data, you may send an e-mail to legal@Itwidl.com or a letter to:
Attn: Legal Department
15455 San Fernando Mission Blvd, Suite 208
Mission HIlls, CA 91345
Please include your registration information you provided through the Services. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.
If you’d like us to delete information that you have provided through the Services, please contact us at legal@Itwidl.com and we will respond in a reasonable time. Please note that some or all of the information you provided may be required in order for the Services to function properly or may be automatically retained in backup storage or records retention archival storage.
Portability of Your Personal Data
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another. Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information under your sole control.
6. Transfer of Data Outside Your Country of Residence
If you are located outside of the United States and you choose to use the Services or provide your information to us, your data may be transferred to, processed and maintained on servers, databases or cloud storage facilities located in the United States. Your use of the Services represents your consent and agreement to these practices. If you do not want your data transferred to or processed or maintained in the United States, you should not use the Services.
We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles of:
Accountability for Onward Transfer
Data Integrity and Purpose Limitation
Recourse, Enforcement and Liability
We have further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
7. The Privacy of Children
The Services are not intended for children under age 16. We do not knowingly collect or distribute personal information from or about children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at legal@Itwidl.com.
8. Security Measures
We provide industry-standard physical, electronic, and procedural safeguards to protect personal data we process and maintain. For example, we take reasonable measures to limit access to this data to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. Please be aware that, although we endeavor to provide reasonable security for data we process and maintain, no security system can prevent all potential security breaches. As a result, we cannot guarantee or warrant the security of any information you transmit on or through the Services and you do so at your own risk.
10. Contact Us
Attn: Legal Department
15455 San Fernando Mission Blvd, Suite 208
Mission HIlls, CA 91345
We will do our best to respond to you in a timely and professional manner to answer your questions and resolve your concerns.