POLICY

Privacy Policy

We respect user privacy and carefully protect all personal data according to global privacy laws and best practices.

[Last Amended: March 26, 2024]

PAYOUTS.COM PRIVACY POLICY

Mrkter Technologies L.B.O. Ltd., operating under the branded name Payouts.com (together with its affiliates companies – “Payouts”, “we”, “our” or “us”) respects your privacy and is committed to protecting your personal data. This privacy policy (“Privacy Policy”) aims to give you information on how we collect, store, use and disclose certain information, including your Personal Data (as such term is defined below) when:

  • A) individuals browsing our website, available at: https://payouts.com/ and the applicable sub-domains and landing pages (“Website”), and interacting with online forms, or engage with our online ads and content, social media interactions (e.g. Facebook, LinkedIn, Twitter), emails or other communications under our control, or whose details are received from partners or vendors, or participate in events that we organize or take part in (collectively, “Prospects”);
  • B) you access and use our platform and the services therein (“Services” and “Customer” respectively), including Customer’s authorized users of the Service, which include employees or representatives (“Customer’s Users”);
  • C) The Customers shares with us, though our platform, certain information concerning individuals to whom payments are made via the Services (“Vendor” or “Payee” as applicable); or
  • D) Individuals that apply for an open position at Payouts through our ‘career page’ available through the Website (“Applicant”).

This Privacy Policy is an integral part of the Website Terms of Use governing Visitors’ (including Applicants) interaction with the Website, and our Services Terms and Conditions, governing Customers’ use of the Services (collectively “Terms“).

Note you are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary.

This policy is provided in a layered format so you can click through to the specific areas set out below.

This privacy policy applies to all individuals in applicable territories; however, certain territories require certain disclosures to be provided in a certain way and format, meaning, we do not process the information differently however there might be differences in the disclosures. Therefore, In the event you are a California resident– please also review our CCPA Privacy Notice to learn more about our privacy practices with respect to the California Consumer Privacy Act.

1. POLICY AMENDMENTS

We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of this Privacy Policy will always be posted on the Website and the update date will be reflected in the “Last Amended” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately, unless we notify otherwise. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.

2. DATA CONTROLLER INFORMATION

Mrkter Technologies L.B.O Ltd.  is the Controller (as such term is defined under the General Data Protection Regulations “GDPR” or equivalent privacy legislation) of the Personal Data we collect from you.

For any question, inquiry or concern related to this Privacy Policy or the processing of your Personal Data, you may contact as follows:

By Email: [email protected]

By Mail: Ha-Sadna’ot St 10, Floor 4, Herzliya, 4673304

Representative for data subjects in the EU and UK Contact Information:

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact in the European Union and the UK regions. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/16629341368.

3. THE DATA WE PROCESS ABOUT YOU

We may collect two types of information from you, depending on your interaction with us.

The first type of information is non-identifiable and anonymous information (“Non-Personal Data”). We are not aware of the identity of the individual from who we have collected the Non-Personal Data. Non-Personal Data, which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, your actions on the Website or Services (such as session duration and page impressions), or approximate geo-location.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Data”).

To clarify, any Non-Personal Data connected or linked to Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.

The table below details the types of Personal Data we process, the purpose, lawful basis, and our processing operations:

Type of DataPurpose of ProcessingLegal Basis (as defined under GDPR)
Prospects

Online Identifiers and Website Telemetry Data:

When you access and interact with our Website, we collect certain online identifiers such as Cookie ID, IP address or similar unique online identifiers generated, advertising ID, tags (“Online Identifiers”).

Further, we will collect your behavioral information, which is collected indirectly by our external marketing tools, or analytic tools. This information includes the referring URL (that is, the webpage directing you to our website, and other websites you visited in the session), your interests in our competitors, the web page you visited when you tapped/clicked on our ad, how you interact with our webpage, time, duration of use, pages you have viewed on our website, activity logs, session recordings (“Telemetry Data”).

Online Identifiers and cookies are used, in particular, to operate the Website and enable its proper functionality, for security and fraud prevention purposes, debugging purposes and to resolve technical problems. For example, in order to automatically recognize you by the next time you enter the Website or to confirm you are a real person.

Online Identifiers and Website Telemetry Data are indirectly collected and processed by third-parties marketing and analytic tools, for analytic and marketing purposes. We process this data to understand how Visitors use our Website and to measure effectiveness of some marketing campaigns we run in order to track conversions, build targeted audience, and market our Services to people who have taken some action on the Website.

Online Identifiers which are collected through cookies we implement, which are strictly necessary for the proper and basic operation of the Website or fraud prevention will be processed based on our legitimate interest.

When we process your Website Telemetry Data for targeting and marketing purposes, we will obtain your consent through our cookie notice and consent management. You may withdraw consent at any time by using the cookie preference settings as available in the footer of the Website, or by managing opt-out through your browser or device.

Contact Information:

If you voluntarily contact us for support or other inquiries, join our waitlist, book a demo, or if you register to receive our newsletter (to the extent available), you will be required to provide us with certain information such as your name, email address, phone number, and additional information regarding your organization. In addition, you can choose to provide us with additional information as part of your correspondence with us, including the actual correspondences, call and video recordings (collectively “Contact Information”).

Newsletter: We will use your Contact Information to share our newsletter.We process such information based on your consent which can be withdrawn at any time by using the “unsubscribe” link within the communications we sent you.

Book a demo: We will use your Contact Information to provide you with the demo services requested.

 

We process such information based on our legitimate interest.
Respond to inquiry: We collect your Contact Information to respond to your inquiry.We process such information based on our legitimate interest.
Improve the services: The correspondence with you may be processed and stored by us to improve our customer service and in the event, we believe it is required to continue to store it, for example, in the event of any claims or in order to provide you with any further assistance (if applicable).When we process your Contact Information on order to improve our customer services, we do so based on our legitimate interest.
Direct Marketing: To the extent available through the Website, when you contact us and book a demo or register for a similar forum, we will use your email address in order to send you service communications and marketing promotions, such as new features, additional offerings, special opportunities or any other information we think you will find valuable (“Direct Marketing”).When we process your email address in order to send you Direct Marketing, we do so based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.
Keep a suppression list: We will further use your email address, if applicable, under our suppression list, when you request to opt-out to ensure we comply with such preference and choice.We process this information subject to our legitimate interest.
Customers

Account Information:

When you create an account and sign up for our Services you will be requested to provide us with certain information such as your contact information, phone number and additional information associated with your account, including your account credentials, including access logs (“Account Information“).

We use the Account Information to create your account, authentication, provide account management (including billing management), customer support and to provide the Services.

Further, your Account Information will be used to provide support services, if and to the extent applicable.

In addition, we use your email address to provide you with Direct Marketing communications.

 

We process your Account Information for account management purposes and providing support services, we do so in order to perform our contract with you.

When we process your email address in order to send you Direct Marketing, we do so based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.

Once you choose to unsubscribe, we will further maintain a suppression file – meaning lists of applicable email addresses that have requested to opt-out, in order to ensure we comply with such preference and choice.

Platform Usage Data:

When you access to and interact with our platform and the Service therein, information regarding such use is automatically generated and collected, which may include the click stream within the platform, the time spent on each page or feature, activity logs, crash data and analytics, how often you use the Service, etc. (collectively “Platform Usage Data“).

We use this information to help us to understand how you are using the Services, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the Service based on the results obtained from this processing.We process this information subject to our legitimate interest.

Transaction Data:

While using the Services, we will process the transactions and related financial information made and provided by Customer and Customer’s Users.

We will use this information to provide you with customer assistance and technical support services, to create aggregated statistical and research data, inferred Non-Personal Data, or anonymized or pseudonymized data (rendered as Non-Personal), which we or our business partners and customers may use to provide and improve our respective Services, or for any other purpose.We will use this data based on our legitimate interest.

Identification Information:

Supplemental documentation may be required by us to verify the identity of Customer’s directors, officers, or owners (who may be Customer’s Users), such as a copy of a government-issued identification card, number of shares, if applicable, or other documentation serving as proof of identity or. This includes any additional data sets Customer’s Users or Customer will choose to provide to us directly through our Know Your Customer (“KYC”) process.

(Collectively “Identification Information”).

We will use (and disclose as further detailed below) the Identification Information and KYC data, to facilitate, operate, and provide our Services, including determining your initial and continued eligibility to use our Services, and to assist in preventing fraud and other financial crimes.

Such information will also be used to comply with legal, regulatory, and other compliance-related requirements.

We will further use the Identification Information to support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.

We will use the Identification Information to perform our contract and enable Customers to open an Account and proceed with payment services and payouts.

We use the information to prevent fraud and illegal financial crime under our legitimate interest, and as required under applicable laws as further detailed below.

Vendors and Payees

Account Information:

Vendors and Payees will be able to access our platform through their dedicated account, whereby we will process such vendors contact details and account information such as email address and password used to create the account, as well as collect access logs (“Vendors Account Information“).

We use the Vendor Account Information to create your account, authentication, provide account management, support services and to provide the Services.

In addition, we use your email address to provide you with Direct Marketing communications.

When we process your Account Information for account management purposes and providing support services, we do so based on our legitimate interest.

When we process your email address in order to send you Direct Marketing, we do so based on our legitimate interest. You can opt-out at any time through the “unsubscribe” link within the email or by contacting us directly.

Once you choose to unsubscribe, we will further maintain a suppression file – meaning lists of applicable email addresses that have requested to opt-out, in order to ensure we comply with such preference and choice.

Platform Usage Data:

When you access to and interact with our platform and the Service therein, information regarding such use is automatically generated and collected, which may include the click stream within the platform, the time spent on each page or feature, activity logs, crash data and analytics, how often you use the platform, etc. (collectively “Platform Usage Data“).

We use this information to help us to understand how you are using the platform, and how to better provide and improve our Services. This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers, decide how to improve the Service based on the results obtained from this processing.We process this information subject to our legitimate interest.

Payment Information:

When using our platform, we will process certain information regarding the Vendors, such as (depending on the applicable vendor) Vendors’ user name, email address, physical addresses, phone number, VAT ID, Social Security Numbers or Tax Identification Number, bank account number, IBAN, SWIFT code (or alternatively, account details at payment processing services) and payment preferences. Supplemental documentation may be required by the Customers, such as a copy of Payee’s government-issued identification card, personal bank statements or other documentation serving as proof of identity or valid address. This includes any additional data you choose to provide to us directly, provided to us by the relevant Customer, banks, payment processing services, your representative, or that we may require.

We process the information as required by applicable laws and to ensure the Customer is able to use the services and conduct payments.

We will use the information to facilitate, operate, and provide our Services, such as facilitating payments, and to determine the initial and continued eligibility to use our Services, and to assist in preventing fraud and other financial crimes.

These data sets are processed by us as a processor on our Customer’s behalf, in accordance with their reasonable instructions in connection with the Services. Therefore, we rely on our Customer’s lawful basis for processing these data sets.

Other data sets are processed by us as a controller based on our legitimate interest.

KYV Data:

Prior to providing certain Services, if and to the extent available and applicable to Customer, our third party service providers might be required to obtain certain information about applicable Vendors from other external sources such as credit bureaus, financial institutions, debt collection agencies, etc. through background checks (and subsequent periodic follow-up soft pull checks) (each a “KYV Check”). Such KYV Check may, without limitation, and depending on the Vendor’s place of establishment, include a review of the following information: (i) credit history, including of a personal or business credit bureau data and score; (ii) criminal records; (iii) information that is publicly available about the Vendor; (iv) information obtained from third party service providers, including information derived or prepared by third-party data aggregation and analysis companies; and (vi) bankruptcy information (collectively “KYV Data“).

We process the KYV Data in order to enable the Customers to use the Services and the Payee or Vendor to receive payments.

 

We process your KYV Data to perform our contract with the Customers and provide our Services.
Applicants

Applicants Information:

When you apply for a job offer we post through our Website, we will process your CV (and the information included therein), as well as additional information such as your Contact Information, information regarding your education and skills, employment history, and your photo (to the extent provided by you).

Further, where required by law, we may process diversity and inclusion data regarding your candidacy, such as ethnicity, gender, or any disability. In addition, we may collect further information from public and online sources, referees, and former employers and combine such data with your other data.

(collectively “Recruitment Information”)

We will use Recruitment Information to process your job application and for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements.

Following the completion of the recruitment process, we may further retain and store the Recruitment Information (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other position we believe you qualify for.

If you are hired, your Recruitment Information will be kept on our HR systems as part of your employment and our corporate management.

We process Recruitment Information subject to our legitimate interest.

In some cases, for example, where we will ask you to provide health related information or diversity and inclusion data, we will process your such data based upon your consent. You may always withdraw consent at any time.

We will retain your data for records keeping and future defense from legal claims under our legitimate interest, or if you have provided consent to contact you in the future.

 

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the “Data Transfer” section 9 below, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms or other agreement, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Information you give us. This is information (including your Contact Information) you consent to giving us about you by filling in forms on the Website, or by corresponding with us (for example, by email or chat).
  • Information we receive automatically. As you interact with our Website and Service, we will automatically collect certain Personal Data, including Telemetry Data and Online Identifiers. We collect this data by using cookies, and other similar technologies as further detailed below.
  • Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources such as external service providers when providing Recruitment Data.

5. COOKIES AND TRACKING TECHNOLOGIES

We use “cookies” (or similar tracking technologies) when you access or interact with the Services. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, for statistical purposes, as well as for advertising purposes. You can find more information about our use of cookies, as detailed under our Cookie Policy.

6. WITH WHOM WE SHARE YOUR PERSONAL DATA

We share your Personal Data with third parties, including our service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.

CATEGORY OF RECIPIENTDATA THAT WILL BE SHAREDPURPOSE OF SHARING
Service ProvidersAll types of Personal Data depending on the each of their specific roles and purposes in facilitating, supporting, and enhancing our ServicesWe engage with selected partners, and third-party contractors to provide certain Services, and to support the operation of our business. Such service providers or contractors include hosting and server co-location services, communications and content delivery networks, internet service providers, operating systems and platforms, data analytics services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, capital providers, and correspondents, customer engagement services, billing, web analytics, e-mail and SMS distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization services, social and advertising networks, content providers, support and customer relation management systems, service providers that help us verify your identity and help us comply with our legal and regulatory obligations to screen and monitor transactions; and our business, legal, tax, financial and compliance advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating, supporting, and enhancing our Services, and may only use it for such purposes.
Financial service provider (“Financial Business Partner”)Account Information, KYC Data, Transaction Data, KYV Data, etc.

In order to provide the financial services we share certain information with our Financial Business Partners such as financial institutions (e.g., banks, credit bureaus, etc.), payment processors, collection agencies, etc. These Financial Business Partners will use the data to provide you with the services and as required under applicable laws or subject to their privacy policy and terms.

Such Financial Business Partners include, without limitation: AirWallex which is our payment processor and will process your Personal Data in accordance with its Privacy Policy available here and its jurisdiction-specific terms and conditions governing your relationship with AirWallex, which you will separately accept while onboarding.

EventsContact InformationWe may receive from, and share with a third-party event host, Personal Data collected at events either managed by us or by a third party. For any event hosted by a third party, the collection and use of all Personal Data will be governed by the applicable third party’s privacy policy, and the terms provided to individuals at the applicable event.
Affiliates or change of controlAll types of Personal DataWe may share your Personal Data internally within our affiliates for the purposes described in this Privacy Policy. In addition, should we or any of its affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant, Personal Data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your Personal Data then-stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
Governmental agencies or authorized third partiesSubject to law enforcement authority request.

We may share certain data when we believe it is appropriate to do so in order to comply with the law enforcement, governmental agencies or authorized third parties, or protect the rights, property, or our security, our Customer’s security, or the security of others.

We may disclose Personal Data to enforce our policies and agreements, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required.

Additional third parties in order to protect certain rights and safetyAll types of Personal DataWe may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Payouts, any of our Customers, Customer’s Users, Vendors or Payees, our Prospects, or any members of the general public.

7. FOR HOW LONG WILL YOU RETAIN MY PERSONAL DATA?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. SECURITY

At Payouts, security is our highest priority. We design our systems with your security and privacy in mind. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry standards. Some of the methods that we use to protect your Personal Data include maintaining compliance programs that validate our security controls, protecting the security of your information during transmission to or from our website, applications, products, or Services by using encryption protocols and software, etc.

Please contact us at: [email protected] if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

9. DATA TRANSFER

Due to our global business operation, your Personal Data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country. However, in all cases, we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer.

We store and process all categories of your Personal Data on our cloud servers located in the EU. However, some of our service providers and business partners are located in various locations, including outside of the EU, EEA or UK. In such events, transfers of your Personal Data will be made in accordance with applicable data transfer mechanism: specifically, if and where Personal Data collected within the EU are transferred outside the EU, to countries which were not granted with an adequacy decision by the European Commission and therefore do not provide an adequate level of protection to your Personal Data while it is transferred to such third country, such transfer is subject to and made pursuant with the standard contractual clauses. Additionally, if and where Personal Data collected within the United Kingdom are transferred outside the United Kingdom, to countries which were not granted with an adequacy decision by the UK Information Commissioner Office (“ICO”) and therefore do not provide an adequate level of protection to your Personal Data while it is transferred to such third-country, such transfer is subject to and made pursuant with the UK standard contractual clauses.

10. YOUR RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, we allow you to exercise your rights, choices, and controls in connection with your information.

In the table below you can review your rights depending on your interaction with us, how you can exercise them, and appeal a decision we take in this regard, any specification per geo-location or territory are available below the table:

RIGHT TO BE INFORMED, RIGHT TO KNOWYou have the right to confirm whether we collect Personal Data or Personal Information about you, if you wish to know if we collect Personal Data about you, please review this Privacy Policy.
ACCESS RIGHTSYou further have the right to know which Personal Data we specifically hold about you, and receive a copy of such or access it, if you wish to receive a copy of the Personal Data or Personal Information, please submit a Data Subject Request form (“DSR”) as available here.
RIGHT TO CORRECTIONYou have the right to correct inaccuracies in your Personal Data, taking into account the nature and purposes of each processing activity. Please submit a DSR as available here.
RIGHT TO BE FORGOTTEN, RIGHT TO DELETIONIn certain circumstances, you have the right to delete the Personal Data we hold about you. Please submit a DSR as available here.
RIGHT TO PORTABILITYYou have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. If you wish to exercise this right, please submit our DSR as available here.

RIGHT TO OPT OUT OR WITHDRAW CONSENT UNDER THE EU, AND IN THE US THE RIGHT TO OPT OUT FROM:

(I) SELLING PERSONAL DATA;

(II) RIGHT TO OPT OUT FROM TARGETED ADVERTISING; AND

(III) RIGHT TO OPT OUT FROM PROFILING AND AUTOMATED DECISION MAKING

Direct Marketing: You have the right to opt-out from Direct Marketing, by unsubscribing through the email received.

Newsletter: you have the right to withdraw consent when you no longer wish to be in our newsletter list.

Cookies: you have the right to cease the performance of certain cookies for analytic and marketing purposes by submitting a DSR form here.

Sale of Personal Data for targeted advertising, monetary gain or profiling, or Share or Sale of Personal Information for analytic or marketing: If and to the extent applicable, you have the right to opt out of the sale of your Personal Data, for the purposes of targeted advertising, sale to a third party for monetary gain, analytic, etc. through the cooking setting on our website, available here.

Last, you are able to install privacy-controls in the browser’s settings to automatically signal the opt-out preference to all websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control, where applicable, subject to your jurisdiction, as a valid request to opt-out of the sharing of information linked to your browser.

Note you may have the right to authorize another person acting on your behalf to opt out (including by technical tools and opt out signals).

RIGHT TO APPEAL OR COMPLAINTIf we decline to take action on your request, we shall so inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Under the EU you have the right to lodge a complaint with the supervisor authority or the Information Commissioner in the UK.
NON-DISCRIMINATIONSuch discrimination may include denying a good or service, providing a different level or quality of service, or charging different prices. We do not discriminate our users.

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, all as detailed under our DSR form, available here.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests, all as detailed under our DSR form, available here.

11. CHILDREN

Our Services are not intended for use by children, and we do not knowingly collect or maintain information about anyone under the age of 18. Please contact us at: [email protected] if you have reason to believe that a child has shared any information with us.

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